3.6 - Contracts

One of the responsibilities for pass-through entities as discussed in Chapter 2 is to determine whether to make a subaward or a contract. Subawards have traditionally followed OMB guidelines. Federal contracts are generally governed under another comprehensive set of federal guidelines, the Federal Acquisition Regulation (FAR). Previously, pass-through entities could have faced requirements to follow both the OMB circulars for monitoring subawards and the FAR when monitoring contracts under grants and cooperative agreements. The uniform guidance has extended some of its provisions to certain contracts (§200.101) that are awarded under grants or cooperative agreements. The… Read More