Subrecipient or Contractor: Making the Right Decision

Webinar • Monday, November 07, 2022 • 2:00-3:30 p.m. ET

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$249.00 Subrecipient or Contractor: Making the Right Decision (11.07.22) (On-Demand Recording)
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

Hundreds of billions of federal dollars are involved in recipients “subawarding” federal funds to other organizations. So, it is not surprising that the Office of Management and Budget, in its “uniform guidance,” seeks to provide clear instructions about whether a “lower tier” organization is to be treated as a subrecipient receiving federal assistance or a contractor being paid for goods and services with federal funds.

Making the corrective determination has very significant management, accountability and oversight implications.

However, when you look at the agreements that document these longstanding arrangements through the prism of the revised federal guidance, the exercise can be daunting and uncertain. This webinar is designed to help you sort out these relationships and to make decisions that are defensible, accountable and acceptable to the players. You’ll gain an understanding about:

  • Distinctions between “assistance” and “procurement” relationships, and why that’s important
  • How the attributes of relationships cited in the federal rules can be just the start
  • The important role that determining eligibility of program beneficiaries plays
  • What the federal rules mean by “responsibility for programmatic decisionmaking”
  • Whether the types of organizations involved has any bearing on the proper determination
  • Which federal laws and executive orders flow to subrecipients, and which ones don’t
  • Which federal laws and executive orders apply to contractors — and which ones don’t
  • How to engage in an informed dialogue with other stakeholders about determination decisions
  • Oversight implications once the decision is made

Join Bob Lloyd, principal of Federal Fund Management Advisor™, to get practical help about how to align what you have been doing with what you should be doing going forward.


  • Finance directors
  • Finance directors
  • Legal counsels
  • Accounting staff
  • Grant and contract managers
  • Sponsored projects administrators
  • Subrecipient monitors
  • Project directors
  • 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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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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