“Do you have a format for a sub-recipient risk assessment to develop monitoring plans?”
“Can you clarify if indirect dollars are subject to the procurement standards?”
These are just some of the questions we received at one of our webinars with grant managers on changes to the 2 CFR Part 200 Uniform Grant Guidance.
In case you missed our live webinar, here is the first part of our three-part series on 10 Essential Questions (and Answers) for Grant Managers:
Question: “Do you have a format for the sub-recipient risk assessment to develop monitoring plans? Is this done annually?”
Answer: There is not an “official” checklist, but you can model the subrecipient assessment on risk assessments and monitoring plans offered by the funding agencies, such as the ones from DOJ at:
Sample Risk Assessment
Sample Subrecipient Monitoring Checklist
We also have a checklist of subrecipient questions at:
The risk assessment and monitoring plan is developed at the beginning of each subaward and you should tackle the format and process even earlier than that.
Then, you want to monitor and make adjustments, as needed, based on things like new awards or reporting of audit findings.
At a minimum, you would review this and document the results annually or more often based on your monitoring plan.
Some other suggestions are:
1) Checking the suspension and debarment exclusions in SAM.gov-do an advanced search on exclusions.
2) Looking up the organization in the Federal Audit Clearing House (aka the FAC.)
You can look up past audit reports and look for prior audit findings under the general information search for audit files.
You can download this information and look at the audit findings tab to determine the types and severity of findings.)
3) Look and see what other types of awards they have on USASpending.gov at https://www.usaspending.gov/.
Search on the recipient to see who is giving them grants and other funding agencies that may also be monitoring them.
Though you wouldn’t solely rely on these databases, you can get a lot of information on potential subaward partners with some research.
Question: “Can you clarify if indirect dollars are subject to the procurement standards?”
Answer: The actual language in 2 CFR Part 200 does not distinguish between direct and indirect costs in application of the procurement standards in sub part 200.320.
However, OMB, in their FAQ (see https://www.cfo.gov/assets/files/2CFR-FrequentlyAskedQuestions_2021050321.pdf), says explicitly that the procurement standards apply to direct costs purchases, not indirect cost purchases.
Sounds too good to be true?
Here’s the catch…
Indirect costs must still be allowable, which means that you must meet all the requirements in 200.403 Factors affecting allowability of costs.
This guidance means you can’t do whatever you want because the costs are indirect.
Question: “What examples would you suggest for sufficient and adequate documentation of grant expenditures?”
Answer: Many of us struggle with this because the rules are more “guidelines” than a hard and fast “checklist.”
In short, you need sufficient documentation for auditors and funding agencies to determine if the costs are allowable-i.e., reasonable, necessary, allocable, and not prohibited by cost principles.
For example, a credit card receipt showing only the purchase amount and not WHAT was purchased would NOT be considered adequate documentation. (For example, you couldn’t tell if someone had an allowable meal or an unallowable beer purchase.)
2 CFR Part 200 talks about a broad range of documentation from personnel expenses, property tracking, and contract administration to indirect cost proposals.
Here are some additional resources that may provide more examples for you:
Grant Management Training with a Greater Purpose
You’ve just gotten a behind-the-scenes look at our approach to grant management training.
We are dedicated to helping grant managers connect on a deeper level to their work and communities as they continue their life-changing work funded by Federal grants.
Stay tuned for Part II of our series focusing on the “naughty” list called FAPIIS. (Hint: It is a new tool in the “accountability” arsenal.)
Ready to Improve Your Grant Management?
How about you?
Would you like to be a better grant manager?
We have another grant management training seminar coming soon.
Click here to get all the details!
Hope to see you there!
Lucy Morgan CPA, MBA
CEO, Compliance Warrior
Author of “Decoding Grant Management – The Ultimate Success Guide to the Federal Grant Regulations in 2 CFR Part 200” The 2nd Edition is now available on Amazon in Paperback and Kindle versions.