The Office of Management and Budget keeps trying. For more than ten years, the agency has sought to provide clear guidance to federal grant recipients that are passing through federal funds to “lower tier” organizations. The “pass-through entities” are supposed to use this guidance to make defensible determinations about whether they are subawarding federal financial assistance to subrecipients or placing procurement contracts with contractors.
There’s no question that the determinations are consequential. They affect how the resulting awards are solicited, provisions contained in legal agreements and how organizations receiving the awards are managed, monitored and, perhaps, audited. OMB’s revised Uniform Guidance (2 CFR 200), which became effective on Oct. 1, 2024, takes another stab at helping pass-through entities clear up their decisionmaking. They’ve added some additional factors to consider but they still rely on other criteria that are often confusing.
Since OMB says that pass-through entities should “exercise judgment” when they make the required determinations, this webinar will take a fresh look at all of the factors that might affect the decision, including some that aren’t included in OMB’s guidance document. We will examine the requirements from the differing perspectives of the federal awarding agencies, the pass-through entities and the lower tier outfits that are receiving the awards.
WHO SHOULD ATTEND:
- Grant managers
- Grant project directors
- Sponsored projects administrators
- Executives
- Finance directors
- Accounting staff
- Purchasing agents
- 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