Recipients and subrecipients of federal grants must follow revised policies contained in the Uniform Administrative Requirements, Cost Principles and Audit Requirements issued by the Office of Management and Budget (OMB) and codified in Title 2 of the Code of Federal Regulations, Part 200. Revisions to these requirements will be effective October 1, 2024.
To assist RDOs in the transition to the revised rules, NADO sponsored a four-part webinar series that provided detailed coverage of key aspects of the new policies. The series was led by Bob Lloyd, who has conducted dozens of NADO sponsored training programs and has provided extensive technical support on the numerous comments that NADO has submitted to OMB urging policy features that recognize the unique role that RDO’s play in many federal grant programs.
In addition to the webinars, Bob Lloyd provided two training sessions at NADO’s 2024 Annual Training Conference (October 21 – 24 in New Orleans, LA): OMB’s Uniform Guidance 3.0–What’s Changed and What Hasn’t? and RDOs in the Middle–Giving and Receiving Federal Grant Subawards. For information about these sessions and the Conference, click here.
Single Audit Readiness and Survival
September 11, 2024, 2:00 – 3:30 pm (ET)
Recording: https://youtu.be/eE2DUFKCIX0
Under requirements of the Single Audit Act and of the Office of Management and Budget’s Uniform Guidance, Subpart F, non-federal organizations that expend more than a threshold amount of federal grants and subgrants during their fiscal year must arrange for a single audit of those funds. Most RDOs expend the threshold amount. Meeting the requirement includes procuring the services of a qualified independent audit firm; preparing accounting records and financial statements; submitting the resulting audit report to the federal government; and following up and resolving any audit findings. Those steps are carried out to serve the underlying objectives of the single audit examination—to determine whether the organization’s financial information is accurate, whether its policies and procedures are well designed and followed, and whether it has complied with applicable laws, regulations, and award terms and conditions. Knowing what tests auditors will perform and what documentation they will be looking for is critical to meeting those objectives particularly since an organization’s “audit history” must be considered by awarding agencies in making decisions about whether to approve a grant and how it will be managed. This session highlighted the changes that OMB has crafted in Subpart F and detailed the practical steps that RDO’s can take to assure a satisfactory audit history.
Grant Cost Allowability 101
September 26, 2:00 – 3:30 pm (ET)
Recording: https://youtu.be/dwkUJl9ukG4
One of the most common questions asked in organizations like RDO’s that expend federal grant funds is “Can we charge this to our grant?” The initial but often unsatisfactory answer is “It depends.” What it depends upon are the federal cost principles that are applicable to those grant awards when a grant or subgrant agreement is issued. The cost principles are a set of rules for determining which costs are allowable charges, which ones are not, and how the costs are to documented. They are called principles because they have to applied to the facts and circumstances that surround particular individual expenditure transactions. Those facts and circumstances can vary widely. So can the people who might have a role in deciding whether a charge is ultimately posted and sustained—program staff, financial managers, executives, board members and even auditors. So, understanding and using the cost principles are essential skills within a federally funded organization. This session analyzed the cost principles contained in Subpart E of 2 CFR 200 with particular emphasis on policies that have been changed in the revisions taking effect on October 1, 2024.
Indirect Cost Recover for RDOs
RESCHEDULED TO October 16, 2024, 2:00 – 4:00 pm (ET)
Recording: https://youtu.be/MsupXJWSHFM
One of the most misunderstood concepts in federal grants management is indirect cost recovery. How does a federally funded organization recover costs that do not benefit a particular grant or subgrant exclusively but are nonetheless necessary for the overall operation of the recipient or subrecipient? The related policy rules now contained in OMB’s Uniform Guidance have been relatively straightforward for years. Because of how those policies interact, many RDOs still face complications as they try to get awarding agencies to bear their fair share of the costs of operating federal grant programs. This session drilled down on the policy details and described in practical terms how they affect the preparation and approval of indirect cost documentation and the acceptance and audit of resulting indirect cost allocation plans and rates.
Purchasing Goods and Services with Federal Grant Funds
October 9, 2024, 2:00 – 3:30 pm (ET)
Recording: https://youtu.be/bojt3TmM75o
“Do we have to get bids?” is a frequently asked question at a federally funded recipient or subrecipient organization. The federal rules apply to grant-funded purchases of supplies, equipment, services, travel, and construction. The procurement standards contained in OMB’s Uniform Guidance (2 CFR 200.317-327) assume that a recipient or subrecipient already has policies for purchasing with their own source revenue. Those policies can continue to apply. But the federal standards introduce numerous situations in which the non-federal organization needs to go beyond their normal practices and to document that they have done so. These include polices about geographic preference; architect, engineering, and audit services; solicitation of disadvantaged businesses; and sole source justifications. OMB has clarified or altered requirements affecting some of these special circumstances in the recent revisions to 2 CFR 200. This session built on 2 CFR 200’s longstanding procurement essentials and highlighted the changes that will affect federally funded purchases going forward.
This webinar series was offered through the NADO Research Foundation’s Economic Development District Community of Practice (EDD CoP). The EDD CoP is made possible through an award from the U.S. Economic Development Administration, U.S. Department of Commerce (ED22HDQ3070106). The statements, findings, conclusions, and recommendations are those of the presenters and participants and do not necessarily reflect the views of the U.S. Economic Development Administration or the U.S. Department of Commerce.