Preventing Subaward Headaches

Recent federal agency audits have homed in on oversight of subawards by pass-through entities. That’s not surprising, because, in a variety of policies, the feds have emphasized that a poor system for monitoring subrecipients elevates the risk of federal program noncompliance. Policies also show that federal officials have an expanded view of what subrecipient monitoring entails.

The requirements for subrecipient management and monitoring in the Uniform Guidance (2 CFR 200) provide a template for what’s required. But they leave a lot of blank space about what also makes sense.

This webinar will fill in that gap with practical advice to implement pre-award preventative measures, detect noncompliance during subaward performance, and avoid additional pass-through entity burden and headaches. We’ll address:

• Are you sure you are making a subaward?
  • Interpreting the characteristics of “lower tier” transactions
• Considering fixed amount subawards
  • Sensible program selection and use
• Soliciting subaward applications
• Selecting subrecipients — need vs. capacity
• Conducting pre-award risk assessment
• Implementing “differential accountability”
  • One size does not necessarily fit all
  • Using alternative provisions in subaward agreements
• Post-award oversight — from a distance and up close
  • Payment
  • Financial and performance reporting
  • Review of single audit reports
  • Deciding on site visit protocols
  • Responding to “extraordinary circumstances”