“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 a few of the questions that we received at our recent update webinar on the changes to 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 performed by the funding agencies, such as the ones from DHS at:
DHS Vulnerability Risk Assessment: http://go.usa.gov/x34dW
I also have a checklist template at:
The risk assessment/monitoring plan should be developed at the beginning of the subaward.
Then you want to monitor and make adjustments as needed based Grant Managers-Part I on things like new awards, or reporting of audit findings.
I think at a minimum you would be reviewing this and documenting the results annually Grant Managers-Part I , or even more often on larger subawards.
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 at for prior audit findings under the general information search for audit files https://harvester.census.gov/facdissem/SearchA133.aspx 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/Pages/default.aspx search on the recipient to see who is giving them grants and therefore other funding agencies that may also be monitoring them.
Though I wouldn’t solely rely on just these databases, you can get a lot of information on potential subaward partners with a little 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 make that distinction between direct and indirect costs in application of the procurement standards in sub part 200.320.
However, OMB in their FAQ (see https://cfo.gov/wp-content/uploads/2015/09/9.9.15-Frequently-Asked-Questions.pdf) and their Q & A Webinar with Gil Tran (on Youtube at https://www.youtube.com/watch?v=lfbKQ9JyM8o specifically say that the Procurement requirements apply to direct costs purchases, not indirect cost purchases.
Sounds too good to be true?
Personally, I would be very wary of ignoring the Procurement Standards for indirect purchases, especially since the governing regulations do NOT make that distinction. 🙂
Question: “What are some examples you would suggest for sufficient and adequate documentation of grant expenditures?”
Answer: This is something many of us struggle with because the rules are more “guidelines” than a hard and fast “checklist.”
In short you need to have adequate documentation sufficient so that auditors and funding agencies can determine if the costs are allowable-i.e. reasonable, necessary, allocable, and not prohibited by cost principles.
For example, a credit card receipt that only shows the amount of the purchase and not WHAT was purchased would NOT be considered adequate documentation. (For example, you wouldn’t be able to tell if someone had an allowable meal, or an unallowable purchase of beer.)
2 CFR Part 200 talks about a broad range of documentation from personnel expenses, property tracking, contract administration to indirect cost proposals, so if you have a specific area of documentation that you find challenging, please put it in the comment box below.
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 professionals connect on a deeper level to their work and communities as they continue their life-changing work funded by Federal grants Grant Managers-Part I .
Stay tuned for Part II of our series next week focusing on the new “naughty” list called FAPIIS. It’s a game changer for grant recipients!
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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.