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Subrecipient Monitoring Tool For Pass-Through Entities

The Association of Government Accountants (AGA) Intergovernmental Partnership members developed a guide to provide a consistent approach for pass-through entities to monitor a grant subrecipient’s compliance with federal administrative requirements. It is designed for use in monitoring the administration of grant dollars provided by federal awarding agencies.

Subrecipient vs. Subcontractor vs. Subaward Designation

I was recently speaking with a client that received two federal grants from two different federal agencies. They began working on the contractor agreements for their vendors, and realized that each agency interpreted 2 CFR 200 (Uniform Grant Guidance or UGG) subaward vs. subrecipient vs. subcontractor terminology very differently. This not only is confusing from an operations standpoint, but can have immediate implications from a transparency perspective if the application is not standardized across the board. Let’s start out with some definitions.

Best Practices for Grantee and Grantor Relationships: Internal Controls

Internal controls – what does this term mean to you as a grant professional? To me, it almost sounds like "mission control." So who is commanding the post? From an accounting perspective, internal controls involve everything that controls risks for an organization, and ensures compliance with applicable laws and regulations (Sawyers Guide for Internal Auditors, The Institute of Internal Auditors Research Foundation, 2012). At the basic organizational level, most policies define internal control objectives as they relate to the reliability of financial reporting, timely feedback on the achievement of operational or strategic goals, and compliance with laws and regulations. Without internal controls, there would be no structure or guidelines with which to manage millions of dollars in public and private funding.

Grantors, Grantees, and Sub-grantees: Roles and Communications

Grant professionals are familiar with the dance that takes place between grantors (those who provide the funding necessary to sustain organizations and government agencies), grantees (the recipients of these funds) and sub-grantees (those who have contractual or grant relationships with grantees). There are many misperceptions about the roles of each group and the intentions behind decisions that are made to support invaluable public services. This article represents the first in a series of posts about these relationships, as an attempt to provide some clarity and demystify the decision-making process behind grantors, grantees, and sub-grantees.

DATA Act: Greater Federal Funding Transparency, Accountability

"American taxpayers deserve to be able to access information about how their money is being spent." - U.S. Representative Darrell Issa, 49th District California

Last month, the House of Representatives adopted H.R. 2061, the Digital Accountability and Transparency Act (DATA Act), introduced by Congressman Darrell Issa. The bill aims to make federal spending more accessible, increase the availability of the data to the public, and improve oversight of federal funding. The legislation is also intended to offer a way to track federal spending, reduce compliance costs, improve transparency, prevent fraud, and improve the quality of data submitted on www.USASpending.gov.

Pass-Through Grants: Sub-awards and the Federal Government

Last week I published a general overview on pass-through grants. This week I’ll discuss federal research sub-awards, the Federal Funding Accountability and Transparency Act, collaborative opportunities, and my experience with pass-through funding.

Pass-Through Grants: What They're All About

The federal government allows grant recipients to act as pass-through entities in order to provide funding to other recipients. The pass-through entity receives federal funds which it “passes on” or “passes through it” to other recipients. The entity that receives funds from a pass-through entity is considered a sub-recipient. This usually occurs when a federal program lacks the organizational capabilities to provide assistance directly to the final recipients and requires support from other entities to do so.

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