Subrecipient Monitoring — Assuring Compliance and Using Best Practices

Webinar • Thursday March 19, 2020 • 2:00-3:30 p.m. ET

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Webinar Details

Prerequisites: Some knowledge of federal grant management and audit requirements is helpful

Recommended Field of Study: Specialized Knowledge and Applications

Program Knowledge Level: Basic

Advanced Preparation: None

When the Office of Management and Budget overhauled rules for managing federal grants and cooperative agreements a while back, a topic that got a lot of attention was subrecipient management and monitoring. OMB recognized that, whether by congressional mandate or program design, large amounts of federal funds are routinely passed through to subrecipients.

Many of these subrecipient do not have any direct relationship with the federal government, so it falls to organizations that are subawarding this money to exercise oversight and make sure that those “lower-tier” entities are expending federal subawards in accordance with laws, regulations and award terms. OMB has mandated some steps that pass-through entities must take. You can be sure that independent auditors are checking to see whether those are that is happening. However, there are still plenty of policy and practice gaps that pass-through entities must address for themselves.

This webinar is designed to help you balance the ongoing risks of working with subrecipients with limited available resources to create a system that addresses your own unique and evolving situation. It will emphasize what you have to do, and help provide you the tools to accomplish related tasks.

You’ll learn about:

  • Regular process review of internal controls over subrecipient monitoring
  • Case-by-case determinations about subrecipient or contractor relationships
  • Requirements for conducting and using risk assessments of subrecipients
  • Mandated terms and conditions for subaward agreements
  • Available flexibility for dealing with high-risk subrecipients
  • Criteria for organizing your subrecipient universe
  • Understanding and employing “differential accountability”
  • Conducting and documenting required subrecipient monitoring steps
  • Making the best use of audit reports of subrecipients who are subject to the Single Audit Act
  • Discretionary monitoring techniques — when and how to use them

For many grant recipients, management and monitoring of their subrecipients can be “an accident waiting to happen.” Join Bob Lloyd, principal of Federal Fund Management Advisor™, for this practical and informative session.


  • Grant and contract managers
  • Sponsored programs administrators
  • Compliance specialists
  • Program managers
  • Finance directors and staff
  • Principal investigators
  • Internal auditors
  • External auditors 

Hand-out Materials:

Attendees will receive presentation slides as well as access to background materials.

Allowable Charges

The costs of webinars sponsored by Federal Fund Management Advisor™ are allowable charges to your federal grants and subgrants. The cost principles issued by OMB under its uniform guidance (and applicable to all types of awardees) state, “The cost of training and education for employee development is allowable” (2 CFR 200.472).

Attend this Live Webinar and Earn up to 1.5 CPE Credits

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Add A Practical Guide to Federal Grants Management -
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This comprehensive resource blends age-old conventional wisdom with the historic changes in OMB’s uniform guidance. You'll benefit from the advice of experts on time and effort reporting, procurement under grants, direct charging certain costs, single audit preparations, subrecipient monitoring and much more. The 500+ page softbound book is a valuable management guide, compliance document and training tool for busy grants managers, program directors, financial officers and auditors at nonprofit organizations, educational institutions, and state and local governments.

This valuable resource will help you and your grants management team:

  • Understand the differences between direct and indirect costs
  • Make the subrecipient vs. contractor determination
  • Realize the full impact of OMB’s emphasis on internal controls
  • Understand which familiar elements of time and effort reporting have been retained in the uniform guidance ... and which are new
  • Know the nuances of requirements for subrecipient assessment and monitoring
  • Understand contract clauses in agreements for procurement under grants
  • Apply the general tests of allowability
  • Understand special issues confronting pass-through entities contracting with foreign organizations
  • Know which clauses flow down when crafting a subaward
  • Understand what is meant by a 10% de minimis indirect cost rate
  • Audit the vulnerabilities in your grants management operation
  • Understand what is meant by audit "resolution"
    ...and much more

A Practical Guide to Federal Grants Management is the best insurance policy there is for limiting your organization’s risk of disallowed costs, loss of federal funding and public relations nightmares. Add it to your order today!

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