An Overview on Subrecipient Monitoring
Articles,  Blog

An Overview on Subrecipient Monitoring


>>I WANTED TO WELCOME ALL OF YOU TO TODAY’S WEBINAR ON AN
OVERVIEW ON SUBRECIPIENT MONITORING SPONSORED BY THE
NONPROFIT SUSTAINABILITY T.A. PROJECT, MY NAME IS ELLEN
YIN-WYCOFF, NSTA SPECIALIST OUT OF THE IOWA COALITION
AGAINST SEXUAL ASSAULT. I’M HERE WITH TWO OF MY
COPRESENTERS AND COLLEAGUES, KAREN NATHAN, FROM KRN
CONSULTING, CINDY SOUTHWORTH. I’M GOING TO LET THE TWO
INTRODUCE THEMSELVES JUST VERY BRIEFLY AS WE BEGIN.
KAREN, WOULD YOU LIKE TO INTRODUCE YOURSELF.
>>SURE, MY NAME IS KAREN NATHAN, I’M A CPA, AND I HAVE
TWO YEARS OF EXPERIENCE IN THE ACCOUNTING FIELD.
I DO SPECIALIZE IN ACCOUNTING AND TAXES FOR NONPROFITS.
AND MANY OF YOU THAT HAVE BEEN ON THE QUARTERLY
COACHING CALLS ALREADY KNOW ME.
AND I’M REAL EXCITED TO BE HELPING PRESENT THIS TOPIC.
>>THANKS KAREN, CINDY, WOULD YOU LIKE TO JUST GIVE A BRIEF
INTRODUCTION.>>SURE.
I’M CINDY SOUTHWORTH, EXECUTIVE VICE PRESIDENT OF
THE NATIONAL NETWORK TO END DOMESTIC VIOLENCE, THE
DISTRICT T.A. PROJECT PARTNER WITH THE RESOURCE SHARING
PROJECT ON THE NONPROFIT SUSTAINABILITY T.A. PROJECT
AND WE ALSO PARTNER WITH RSP ON MANY T.A. INITIATIVES, AND
I OVERSEE OUR FINANCE DEPARTMENT, AND SO I’M HAPPY
TO BE ON THE CALL WITH YOU ALL TODAY.
>>THANKS CINDY. AND AGAIN, MY NAME IS ELLEN
YIN-WYCOFF, NTSA SPECIALIST. I’M ACTUALLY NOT BASED IN
IOWA BUT CALIFORNIA AS A REMOTE EMPLOYEE WITH THE
RESOURCE SHARING PROJECT. AGAIN, WE ARE AN OVW T.A.
PROVIDER THAT WE RECEIVED A GRANT ABOUT, OH, ABOUT TWO
YEARS AGO FOR THE NONPROFIT SUSTAINABILITY T.A. PROJECT,
AND BASICALLY WE ARE A PROJECT OUT OF THE NATIONAL
SEXUAL ASSAULT RESOURCE SHARING PROJECT OUT OF
IOWACASA AND DO THIS IN PARTNERSHIP WITH THE NATIONAL
NETWORK TO END DOMESTIC VIOLENCE.
THIS PROJECT IS FUNDED BY OVW AND YOU CAN SEE THE REQUISITE
DISCLAIMER THAT WE HAVE, TO PROVIDE THE FINDINGS AND
CONCLUSIONS OUT OF THIS PROGRAM ARE THOSE OUT OF THE
NTSA PROJECT AND DOESN’T NECESSARILY REFLECT THE VIEWS
OF OVW. AND SO CINDY IS GOING TO TELL
US A LITTLE BIT MORE ABOUT WHAT WE DO THROUGH NTSA.
>>ABSOLUTELY. WE HAVE SMALL TECHNICAL
ASSISTANCE PROJECTS, ONE FULL-TIME PROJECTS, WHICH IS
THE FABULOUS ELLEN, SHE IS FANTASTIC AND A GREAT
RESOURCE FOR ALL OF YOU. WE HOST WEBINARS AND TRY TO
FOLLOW IT UP WITH COACHING CALLS WHERE WE DO ONE ON ONE
PEER SHARING WHERE PEOPLE PITCH IN WITH TOPICS AND ASK
QUESTIONS AND SHARE THEIR OWN STRATEGIES.
WE HAVE BEEN CREATING TIP SHEETS.
THERE WAS ONE ON PROGRAM INCOME FOR GOVERNMENT
GRANTEES, OVW GRANTEES, THOSE TYPES OF THINGS, AND OTHER
TOOLS, AND THERE’S ALSO INDIVIDUALIZED T.A. BY PHONE
AND E-MAIL. SO IF YOU DO NEED SUPPORT,
PLEASE REACH OUT TO ELLEN. IF SHE DOESN’T HAVE THE
ANSWER SHE WILL REACH OUT AND GET IT EITHER FROM US OR OVW
OR GO TO THE FFATA FOLKS AS YOU WILL HEAR ABOUT LATER
TODAY.>>THANKS CINDY.
SO AT THE BOTTOM OF THIS PARTICULARS SLIDE YOU WILL SEE THE LINK TO
OUR WEB PAGE THAT HAS THE RESOURCES AND TOOLS THAT WE
ARE HIGHLIGHTING IN THE NEXT SLIDE, THAT I WON’T GO INTO
GREAT DETAILS BUT THESE ARE RESOURCES ON OUR WEB PAGE.
EARLY ON AT THE BEGINNING OF THE PROJECT THAT MANY OF YOU
PLAY HAVE SAT IN, WE DID A WEBINAR SERIES ON THE UNIFORM
GRANT GUIDANCE, CALLED THE NEW UNIFORM GUIDANCE AT THE
TIME, WHICH IS WHERE ALSO THE SUBPOENA RECIPIENT MONITORING
THAT WE ARE COVERING TODAY HIGHLIGHTS SOME OF THE KEY
POINTS ON OUT OF THE UNIFORM GRANT GUIDANCE.
SO YOU CAN FIND A LOT OF THAT INFORMATION IN OUR PRIOR
RECORDED WEBINARS. WE ALSO HAVE THE HANDOUTS AND
ALL OF THAT AVAILABLE ON THE WEB PAGE.
ALSO, SOME VARIOUS TOOLS THAT WE HAVE DEVELOPED OUT OF NTSA
THAT CAN FURTHER ASSIST YOU. WE ALSO CREATED FACT SHEET,
SPECIFICALLY ON SUBRECIPIENT MONITORING WHICH WILL BE
SENDING OUT TO YOU FOLKS AGAIN THAT COVERS SOME OF THE
DETAILS AND SOME OF THE KEY POINTS OUT OF THE UNIFORM
GRANT GUIDANCE, SPECIFICALLY AS IT RELATES TO SUBRECIPIENT
MONITORING. SO AGAIN, THESE ARE SOME OF
THE RESOURCES WE REALLY ENCOURAGE YOU, IF YOU HAVEN’T
TAKEN A LOOK AT THEM, TO FREE FREE TO GO TO OUR WEB PAGE
AND LOOK AT RESOURCES THAT CAN BE ADAPTED FOR YOUR USE
OR UTILIZING IN TERMS OF HELPING YOU TO HELP YOUR
AGENCY TO BE ABLE TO RUN MORE EFFECTIVELY OR TO ADDRESS
SOME OF THE PARTICULAR ISSUES OR QUESTIONS THAT YOU MAY
HAVE. SO THE NEXT SLIDE IS JUST TO
KIND OF GIVE YOU A QUICK OVERVIEW ABOUT UTILIZING I
LINK, THE WEBINAR SYSTEM THAT WE ARE UTILIZING.
OBVIOUSLY IF YOU’VE GOTTEN AUDIO YOU ARE EITHER
UTILIZING THE ADO THROUGH THE I LINK, THROUGH THE INTERNET,
OR YOU CAN CALL IN ON THE CONFERENCE LINE.
SHOULD YOU EXPERIENCE ANY PROBLEMS WE CERTAINLY
ENCOURAGE TO YOU CALL ON THIS CONFERENCE LINE AND CALL THE
PARTICIPANT CODE, IN THE LEFT HAND CORNER, TO GET THE AUDIO
FOR TODAY’S WEBINAR. IF YOU ARE EXPERIENCING ANY
TECHNICAL DIFFICULTIES, YOU CAN CERTAINLY CONTACT I LING
AND THE NUMBER IS REPRESENTED THERE.
WE ENCOURAGE YOU TO UTILIZE THE CHAT BOX IN THE LOWER
RIGHT HAND CORNER WHICH MANY OF YOU HAVE ALREADY.
IF YOU HAVE ANY QUESTIONS ABOUT SOME OF THE TOPICS THAT
WE ARE COVERING IN TODAY’S WEBINAR, FEEL FREE TO TYPE IN
THE CHAT BOX. WE ALSO KNOW SOME OF YOU HAVE
LISTED SPECIFIC QUESTIONS DURING IN YOUR REGISTRATION,
DURING THE COURSE OF REGISTRATION.
WE HAVE INCORPORATED MANY OF THOSE INTO TODAY’S
PRESENTATION. WE KNOW THAT SOME OF YOU HAVE
ASKED SPECIFIC QUESTIONS, A LITTLE OUTSIDE OF SCOPE OF
TODAY’S WEBINAR, BUT MY INTENTIONS ARE TO FOLLOW UP
WITH YOU OR CERTAINLY COURAGE YOU TO E-MAIL ME OR CONNECT
WITH ME AFTERWARDS, AFTER TODAY’S WEBINAR, AND I WOULD
CERTAINLY BE ABLE TO ADDRESS THOSE QUESTIONS FOR YOU.
WE ARE ALSO RECORDING TODAY’S WEBINAR AND THE LINK WILL BE
E-MAILED WITHIN THE NEXT COUPLE OF WEEKS, AFTER WE
UPLOAD IT ON TO OUR WEB PAGE. THEN ALSO AT THE END OF THIS
PRESENTATION WE WILL HAVE AN ONLINE EVALUATION THAT I WILL
BE SENDING IT OUT VIA E-MAIL THAT WE WOULD LIKE TO GET
YOUR FEEDBACK ON TODAY’S WEBINAR.
WHAT I WOULD LIKE TO DO IS TURN IT TO CINDY FOR THE NEXT
POLLING QUESTION.>>WE WOULD LOVE TO KNOW WHO
ALL CAN ON THE CALL AND WHAT YOUR ROLE OR POSITION IS AT
YOUR AGENCY. SO IF YOU ARE THE EXECUTIVE
DIRECTOR, IF YOU COULD SELECT A ON THE POLL THAT YOU WILL
SEE IN A MOMENT, BOARD MEMBER, FINANCE OR
ADMINISTRATIVE STAFF, OR D IS PROGRAM STAFF.
THAT’S ON THE LEFT ABOVE THE CHAT BOX.
AND, AGAIN, IT’S A, EXECUTIVE DIRECTOR, B, BOARD MEMBER, C,
FINANCE OR ADMINISTAFF, D, PROGRAM STAFF.
SO IF YOU CAN SELECT THAT, IT WOULD BE VERY HELPFUL.
>>AND PROGRAM STAFF MEANS PROGRAMMATIC STAFF, PEOPLE
THAT ARE DOING THE SORT OF NUTS AND BOLTS OF THE ACTUAL
PROJECT, VERSUS THE BACK END INFRASTRUCTURE.
>>AND WE WILL SEE THE ANSWERS IN A MOMENT.
>>WE’VE GOT A BUNCH COMING IN BY THE CHAT BOX, SO WE’VE
GOT LOTS OF FINANCE AND ADMINISTAFF CHATTING AWAY, A
COUPLE OF EXECUTIVE DIRECTORS.
>>AND ELLEN WILL HOPEFULLY BE ABLE TO SHOW THE RESULTS
BASED ON HOW HAPPY THE WEBINAR SYSTEM IS WITH US
TODAY. LAST CALL FOR ANY OF THE
POLLING QUESTION ANSWERS.>>OKAY, CINDY, I THINK — I
DON’T KNOW IF IT’S SHOWING UP ON YOUR SCREEN BUT I HAVE IT
SHOWING UP ON MY SCREEN, IT LOOKS LIKE THE MAJORITY THE
FOLKS ARE FINANCE AND ADMINISTRATIVE STAFF, ABOUT
68 PERCENT OF THEM, REGISTERING AS SUCH,
15 PERCENT THAT ARE EXECUTIVE DIRECTORS, AND 16 PERCENT
THAT ARE PROGRAM STAFF.>>GREAT.
THANKS SO MUCH.>>SO KAREN, WOULD YOU LIKE
TO GO OVER THE NEXT SLIDE?>>SURE.
FOR THE LEARNING GOALS FOR THIS WEBINAR, WE WANT TO
PROVIDE YOU WHAT THE DEFINITIONS OF WHAT THE
SUBRECIPIENT CONTRACTOR AND SUBAWARD ARE AND THE
DIFFERENCES. I KNOW AT TIMES PEOPLE TEND
TO USE THESE TERMS INTERCHANGEABLY BUT WE WANT
TO GIVE YOU A GOOD DEFINITION 7 SO THAT WHEN YOU READ WHAT
YOU READ TO DO WITH EACH, THAT YOU WILL UNDERSTAND IT.
WE ALSO WANT TO PROVIDE AN OVERVIEW OF THE CONTRACT
REQUIREMENTS FOR SUBRECIPIENTS, WHICH WILL
INCLUDE BOTH THE PREAWARD AND RISK ASSESSMENT THAT NEEDS TO
BE DONE. WE ARE GOING TO IDENTIFY
CONTRACT ELEMENTS FOR THE SUBRECIPIENTS, AND WE ARE
GOING TO ADDRESS MONITORING REQUIREMENTS FOR
SUBRECIPIENTS, WHICH I KNOW CAME UP IN QUITE A NUMBER OF
QUESTIONS. AND AGAIN, I WANT TO
EMPHASIZE THAT THIS IS FOR SUBRECIPIENT MONITORING AND
WE WILL NOT BE ABLE TO ADDRESS ANY ISSUES THAT
RELATE TO PASS-THROUGH FUNDING.
TO GO ON TO THE NEXT SLIDE, WE ARE GOING TO TALK ABOUT
FIRST WHAT THE DIFFERENCE IS BETWEEN A SUBRECIPIENT AND A
CONTRACTOR IS. A SUBRECIPIENT IS SOMEONE
THAT IS GOING TO SERVE AS YOUR PROJECT PARTNER VERSUS
SOMEONE THAT YOU ENGAGE WITH TO PROVIDE GOODS OR SERVICES.
SO IN OTHER WORDS, THE SUBRECIPIENT IS SOMEBODY THAT
YOU ARE GOING TO REALLY PARTNER WITH, NOT JUST
CONTRACT FOR. THE SUBRECIPIENT’S
PERFORMANCE IS GOING TO BE MEASURED AGAINST THE
OBJECTIVES IN YOUR GRANT, THEY WILL ALSO BE RESPONSIBLE
FOR PROGRAMMATIC DECISION MAKING, AND, LASTLY, BUT NOT
LEASTLY, THEY WILL REQUIRED TO COMPLY WITH THE UGG, AND
AS YOU CAN SEE THE A THE 8 BOTTOM OF THE SLIDE, WE PUT
THE UGG SOURCE CODES IN THERE, SO THAT YOU CAN GO
BACK AFTER THIS WEBINAR AND READ THIS FOR YOURSELF.
>>AND KAREN, FOR THOSE ONLY LISTENING AND NOT READING THE
SLIDES, THE UGG STANDS FOR UNIFORM GRANT GUIDE.
>>YES, NOW TO GO ON TO CONTRACTOR, A CONTRACTOR IS
SOMEONE THAT YOU HIRE TO PROVIDE NORMAL GOODS AND
SERVICES. FOR INSTANCE, I’M A
CONTRACTOR. I CONTRACT WITH NNEDV TO
PROVIDE THEM ACCOUNTING SERVICES.
YES I WORK ON FEDERAL GRANT, BUT NO, I’M NOT A
SUBRECIPIENT. I MAKE NO DECISIONS ABOUT HOW
THE GRANTS ARE TO BE RUN, WHAT PROGRAM OBJECTIVES ARE
TO BE ACCOMPLISHED, NOTHING LIKE THAT.
I AM JUST A NORMAL CPA, I PROVIDE GOODS AND SERVICES
WITHIN A NORMAL BUSINESS OPERATION AND ANCILLARY TO A
FEDERAL GRANTS PROJECT.>>AND AGAIN, WE’VE GOT THE
LINKS. NOW, THIS NEXT SLIDE IS A
CHART THAT IS A PRETTY GOOD PRESENTATION OF THE
DIFFERENCE BETWEEN A SUBRECIPIENT AND A
CONTRACTOR. FOR THE INSTANCE, THE TOP
LINE, AN MOU PARTNER, MOU BEING MEMORANDUM OF
UNDERSTANDING. WHEN YOU HAVE AN MOU WITH
SOMEONE, THEY ARE GENERALLY CONSIDERED TO BE A
SUBRECIPIENT, BECAUSE YOU ARE NOT GOING TO DO AN MOU WITH A
CONTRACTOR. 9 WITH A CONTRACTOR, YOU ARE
GOING TO DO A REGULAR BUSINESS TYPE OF CONTRACT.
SO IF YOU GO DOWN THIS LIST, AND YOU ANSWER YES OR NO,
THIS WILL HELP YOU DECIDE WHETHER OR NOT THE OTHER
ENTITY OR PERSON THAT YOU ARE GOING TO BE DOING BUSINESS
WITH IS A SUBRECIPIENT OR A CONTRACTOR.
AND THIS SLIDE WAS USED IN OVW TRAINING FROM A COUPLE OF
YEARS AGO.>>KAREN, THIS IS CINDY.
JUST A QUICK ADDITIONAL NOTE ON THAT.
SOMETIMES, WHEN YOU ARE RUNNING A GRANT, YOU MIGHT
HAVE A CONSULTANT WHO IS NOT PROVIDING GOODS AND SERVICES
LIKE ACCOUNTING SERVICES BUT SOMEBODY YOU CONTRACT WITH TO
COME AND FACILITATE A WORKSHOP OR SESSION, OR MAYBE
YOU PAY THEM TO SPEAK AT A TRAINING OR WORKSHOP, AND
IT’S A VERY NARROWLY DEFINED ACTIVITY.
THEY DON’T HAVE GRANT MAKING OR DECISION MAKING OVER THE
GRANT ACTIVITIES. THEY ARE NOT HELPING
IMPLEMENT THE ENTIRE GRANT. BUT THEY ARE BEING CONTRACTED
WITH FOR A NARROWLY SCOPED CONSULTING GIG.
BY OUR DEFINITION AND BY WHAT WE READ THROUGH THE UNIFORM
GRANT GUIDANCE AND WHAT UVW HAS PUT OUT, A CONTRACTOR NOW
WOULD SILL NOT BE A SUBRECIPIENT, A SUBRECIPIENT
IS SOMEBODY YOU TYPICALLY THINK OF AS A GRANT PARTNER
WHO IS DOING A LARGE PROJECT OR CHUNK OF WORK AND THEY DO
HAVE INDEPENDENT DECISION MAKING.
>>RIGHT. 10 EVEN THOUGH THIS IS A REALLY
GOOD CHART TO HELP YOU DECIDE, ON EACH AGREEMENT, AS
YOU ENTER INTO, YOU’RE GOING TO HAVE TO USE YOUR JUDGMENT
ON WHAT BUCKETS THE ORGANIZATION FALLS INTO, ARE
THEY REALLY A SUBRECIPIENT, OR ARE THEY A CONTRACTOR.
AND AS WE GO ON TO THE NEXT SLIDE, WE’VE GOT ANOTHER
QUICK POLLING QUESTION FOR YOU, WHICH OF THE FOLLOWING
IS A CHARACTERISTIC OF A SUBRECIPIENT, A, DOES NOT
NEED TO COMPLY WITH THE FEDERAL PROGRAM REQUIREMENTS
AND UGG, B, PERFORMANCE IS MEASURED AGAINST THE GRANT
OBJECTIVES, C, IS NOT AN MOU PARTNER, D, NORMALLY OPERATES
IN A COMPETITIVE ENVIRONMENT. AND AGAIN, THERE IS A BOX FOR
YOU TO CHECK YOUR ANSWER.>>THE BOX SHOULD BE RIGHT
ABOVE THE CHECK BOX AND WE HAVE FOLKS THAT ARE
RESPONDING. SO IT LOOKS LIKE ABOUT —
WELL, FOLKS ARE STILL RESPONDING.
KAREN? YEAH, I CAN’T SEE THE ANSWERS
UP ON MY SCREEN FOR WHATEVER REASON.
>>OKAY. WE HAVE 85 PERCENT OR MORE
RESPONDING WITH LETTER B, PERFORMANCE WAS MEASURED
AGAINST THE GRANT OBJECTIVES, A FEW FOLKS, ABOUT 4 PERCENT,
THAT HAVE RESPONDED C, AND ABOUT 9 PERCENT, 7-9 PERCENT,
THAT ARE RESPONDING D.>>IT IS NOW LOOKING LIKE WE
HAVE ABOUT 89 PERCENT OF THE PARTICIPANTS ARE RESPONDING
B, PERFORMANCE IS MEASURED AGAINST THE GRANT OBJECTIVE.
>>SO KAREN, DO YOU WANT TO 11 TALK ABOUT THE RESPONSE TO
THE QUESTION?>>SURE.
SURE. THE CORRECT ANSWER FOR THIS
QUESTION IS B, PERFORMANCE IS MEASURED AGAINST THE GRANT
OBJECTIVE. AND IF YOU HAD GONE BACK TO
THE SCREEN PRIOR TO THAT, THAT WAS ONE OF THE ITEMS
THAT WAS A CHARACTERISTIC OF A SUBRECIPIENT.
OKAY, SO NOW WE’RE GOING TO GO INTO BRIEFLY A DEFINITION
OF WHAT A SUBAWARD IS, AND SO THE SUBAWARD IS BASICALLY
WHAT YOU COULD CALL THE CONTRACT OR AGREEMENT THAT
YOU ARE GOING TO BE PUTTING TOGETHER WITH THE
SUBRECIPIENT OR MOU PARTNER, AN AWARD OF THE FEDERAL FUNDS
FROM FROM THE PRIME GRANTEE WHO WILL BE DOING
SUBRECIPIENT GRANTING AND THAT CONTRACT WOULD BE CALLED
A SUBAWARD. SINCE YOUR AGENCY IS THE
DIRECT RECIPIENT OF THE DIRECT FEDERAL AWARD.
AND THAT’S THEIR ROLE, AGAIN, AS WE TALKED ABOUT, THAT THEY
WILL BE HELPING TO CARRY OUT THE GRANT DELIVER ANNUALS FOR
THE FEDERAL AWARD ON YOUR BEHALF.
AND THAT THE SUBAWARD CAN BE DEVELOPED IN THE FORM OF A
LEGAL AGREEMENT SUCH AS A CONTRACT, QUITE OFTEN IN YOUR
GRANT APPLICATIONS, YOU ARE REQUIRED TO PROVIDE AN MOU,
DESIGNATING YOUR SPECIFIC PARTNERS OR SUBRECIPIENTS AND
IT’S BASICALLY AN AGREEMENT BETWEEN YOU, WHICH WOULD BE
THE PRIME GRANTEE, AND SUBRECIPIENT.
THE SUBAWARDS ARE NOT SUBJECT 12 TO PROCUREMENT STANDARDS AS
WE HAVE COVERED IN THE PRIOR SLIDE OR SOLE SOURCE
AGREEMENTS AS THEY ARE LISTED IN YOUR GRANT AWARD OR GRANT
APPLICATION, AND THAT YOU ARE INCLUDING THAT INFORMATION
WITHIN THE SCOPE OF THE APPLICATION AND THAT IF YOUR
GRANT AWARD IS APPROVED, THAT THAT WOULD BE INCLUDED WITH
THAT. WHAT’S ALSO IMPORTANT IS THAT
WE ARE GOING TO BE COVERING MORE DETAILS FURTHER ON IN
TODAY’S PRESENTATION ABOUT WHAT ARE THE ITEMS THAT NEED
TO BE INCLUDED IN THE AGREEMENT THAT YOU HAVE WITH
YOUR SUBRECIPIENT. WE WILL BE GOING INTO THAT IN
A LITTLE MORE DEPTH.>>THEN WE ARE GOING TO MOVE
TO THE NEXT SLIDE. HERE ARE SOME OF THE ITEMS
THAT ARE TYPICALLY REQUIRED PRIOR TO YOU ENTERING INTO A
SUBAWARD WITH YOUR SUBRECIPIENT.
THESE ARE SOME ITEMS THAT ARE RECOMMENDED OR THAT YOU
SHOULD BE COLLECTING AND REVIEWING FROM THE
SUBRECIPIENT BEFORE YOU GO INTO A FINAL AGREEMENT WITH
THEM, THAT YOU SHOULD BE COLLECTING THEIR FINANCIAL —
A COPY OF THEIR FINANCIAL MANAGEMENT POLICES OR MANUAL,
YOU SHOULD BE REVIEWING THOSE ITEMS TO MAKE SURE THAT THEY
HAVE GOOD INTERNAL CONTROLS, GOOD OVERSIGHT, JUST AS THEY
WOULD IF THEY ARE GOING TO BE RECEIVING FEDERAL FUNDS
THROUGH YOUR ORGANIZATION. THE OTHER THING WE RECOMMEND
IS THAT YOU ALSO RECEIVE FROM THEM THEIR LAST OR MOST
RECENT AGENCY AUDIT, 13 INCLUDING THEIR MANAGEMENT
LETTER, AND BASICALLY, WHAT YOU ARE LOOKING FOR, WHICH WE
WILL GO INTO MORE DETAIL WHEN WE TALK ABOUT RISK
ASSESSMENT, IS SEEING IF THERE ARE PARTICULAR
MANAGEMENT CONCERNS OR FINDINGS AND HOW THE AGENCY
HAS RESPONDED TO THOSE FINDINGS AS THEY MAY HAVE
BEEN RAISED IN THE INDEPENDENT OUGHT.
AGAIN THEIR AGENCY WOULD ONLY BE SUBJECT TO AN AGENCY AUD
FIT THEY MEET THE THRESHOLD WHERE THEY RECEIVED MORE THAN
$750,000 IN FEDERAL FUNDS. THE OTHER ITEM THAT WE
ENCOURAGE TO YOU COLLECT IS ALSO THE MOST FEDERAL TAX
RETURNS, THE 990S, MAKING SURE THAT YOU REVIEW THEM,
MAKE SURE THAT THEY HAVE KEY ELEMENTS IN PLACE IN TERMS OF
BOARD OVERSIGHT AND REVIEW, SPECIFICALLY IF THEY HAVE A
CONFLICT OF INTEREST POLICY, AND ALSO, WHISTLEBLOWER
POLICY, WHICH ARE KEY ELEMENTS THAT ARE JUST PART
OF GOOD GOVERNANCE FOR AN ORGANIZATION, ALSO TO ENSURE
THAT THERE ARE PARTICULARLY — THAT THAT SERVES AS AN
OPPORTUNITY TO AVOID ANY PARTICULAR CONCERNS OR
FINDINGS THAT TYPICALLY COME UP IN INDEPENDENT AUDITS, AND
ALSO, THEY SHOULD BE AUDITED BY ANY OF THE FUNDERS.
THE LAST THING THAT WE ALSO RECOMMEND IS YOU GET BOARD
MEETING MINUTES THAT SPECIFICALLY COVER THE
BOARD’S REVIEW OF THE AUDIT AND THE TAX RETURNS.
SO KAREN OR CINDY, IS THERE ANYTHING ELSE YOU WANT TO ADD
BEFORE WE MOVE ON? 14>>OKAY, IF NOT I’M GOING TO
GO AHEAD AND MOVE TO THE NEXT SLIDE AND HAVE CINDY COVER
THAT.>>GREAT.
ONE OF THE THINGS THAT IS IMPORTANT TO DO BEFORE YOU
AWARD MONEY TO A SUBRECIPIENT IS TO MAKE SURE THAT YOU
CHECK AND FIND OUT IF THEY HAD BEEN DEBARRED OR
SUSPENDED FROM RECEIVING FEDERAL FUNDS.
AND THE MAIN WEBSITE TO DO THAT FROM IS THE U.S.
GOVERNMENT’S WEBSITE, ON THE WEBSITE HERE, IT’S
WWW.SAM.GOV/PORTAL/SAM/ HASHTAG ONE.
SUPER EASY TO REMEMBER, RIGHT?
THAT’S THE WEBSITE YOU GO AND YOU PUT IN THE ORGANIZATION
NAME THAT YOU ARE HOPING TO USE AS A SUBRECIPIENT AND IT
WILL COME BACK AND HOPEFULLY SAY NO RESPONSES FOUND, AND
IF IT DOES, YOU NEED TO — IF SOMETHING DOES POP UP, YOU
NEED TO CONFIRM THAT’S ACTUALLY THE RIGHT
ORGANIZATION, BECAUSE SOMETIMES, THERE ARE
ORGANIZATIONS THAT HAVE SIMILAR NAMES, SO YOU WANT TO
MAKE SURE YOU ARE LOOKING AT — IF ONE DOES SHOW UP IT
TRULY IS THE SUBRECIPIENT YOU ARE HOPING TO CONTRACT W. NOT
JUST SOMETHING WITH A VERY SIMILAR NAME.
IT’S SORT OF BEST PRACTICE, YOU WANT TO DOCUMENT THAT
PRACTICE. I KNOW SOME ORGANIZATIONS
WILL DO SORT AFTER SCREEN SHOT OR PRINT A PDF OR A
PAPER COPY OF THAT SEARCH RESULT COMING BACK AS ZERO
RESPONSES. 15 IF YOUR BROWSER PUTS THE DATE
ON IT ALREADY, WHEN YOU GO TO PRINT, IT SHOULD SHOW THE
DATE THAT YOU CHECKED IT, WHICH OBVIOUSLY YOU WANT IT
TO BE BEFORE YOU CONTRACT WITH THEM AND START GIVING
THEM FUNDS. IF IT DOESN’T PRINT THE DATE
ON IT BECAUSE OF YOUR BROWSER SETTINGS, THE OTHER OPTION IS
YOU MAY WANT TO GO AHEAD AND PRINT IT, THEN SIGN AND DATE
IT, SO THAT IT SHOWS THE DATE YOU DID THAT CHECK.
SOME OTHER ORGANIZATIONS HAVE A CHECKLIST, AND THEY LIST
ALL THESE DIFFERENT STEPS, AND WHEN THE PERSON CHECKS
THE FEDERAL GOVERNMENT WEBSITE AND THEN THE STATE
WEBSITE, THEY SORT OF INITIAL OR SIGN AND DATE THE DATE
THAT THEY CHECKED AND MADE SURE THAT THERE WAS NOTHING
RESPONDED. IN TERMS OF THE STATE SITE,
THEY ARE LISTED HERE, AND IT’S WWW.GSAIG.GOV/NODE/31,
AND WHEN YOU GO TO THAT WEBSITE, YOU CLICK ON THE
STATE, AND FOR EXAMPLE, WHEN I CLICKED ON THE VIRGINIA
STATE, THERE’S REALLY ONLY ABOUT SEVEN PAGES OF
ORGANIZATIONS THAT HAVE BEEN PREVENTED FROM RECEIVING
FEDERAL FUNDS, AND THEY ARE LISTED ALPHABETICALLY.
SO WHILE THEY DON’T HAVE THE SAME SEARCH FUNCTIONALITY
THAT THE FEDERAL GOVERNMENT WEBSITE DOES, YOU CAN QUICKLY
LOOK THROUGH IT AND MAKE SURE THAT THE SUBRECIPIENT YOU
WANT TO USE IS NOT LISTED. THE BIGGEST THING IS TO MAKE
SURE ONCE YOU DO THOSE CHECKS TO DOCUMENT IT SOMEWHERE,
EITHER IN A CHECKLIST WITH 16 THE DATE AND INITIALS OR
SIGNATURES OF WHO DID THE CHECK, OR DO A — PRINT THE
SCREEN OF THE CHECKING OR PRINT THE SCREEN SHOT SHOWING
NO RESULTS. THAT’S ALL I GOT.
>>CINDY, I THINK THERE’S A QUESTION THAT CAME IN, THE
SEARCH THROUGH SAM DOES NOT SHOW, THE NAME SEARCHED
ANYMORE, ONLY THERE’S NO RESULTS, AND ANY
RECOMMENDATIONS OR SUGGESTIONS ON IF THAT’S
APPROPRIATE ENOUGH DOCUMENTATION, OR IF THERE’S
ANYTHING YOU SHOULD DO.>>GIVEN THAT, WHAT WE COULD
DO IS A SCREEN SHOT, WHERE YOU DO A SCREEN CAPTURE, AND
IT’S TYPICALLY CONTROL ALT PRINT SCREEN, BUT YOU COULD
ACTUALLY DOCUMENT THAT YOU LOOKED FOR THE ORGANIZATION
BY NAME AND SIGN AND DATE IT. WHEN WE’VE BEEN TESTED BY
AUDITORS, THEY WANT TO ENSURE WE FOLLOW THE PROCESS AND
DOCUMENT THAT WE FOLLOWED THE PROCESS.
BUT I THINK THE SCREEN SHOT IS LESS RELEVANT THAN SHOWING
THAT YOU ACTUALLY FOLLOWED YOUR OWN STEPS.
>>ALL RIGHT. AND THE FOLLOWUP QUESTION
THAT CAME FROM ANOTHER PARTICIPANT, HOW OFTEN IS THE
DEPARTMENT TEST REQUIRED, ANNUALLY OR WHEN?
>>IT’S REQUIRED BEFORE YOU CONTRACT WITH THEM.
SO IF YOU ARE GOING TO DO A MULTI-YEAR AGREEMENT YOU NEED
TO MAKE SURE BEFORE YOU SIGN THAT MULTI-YEAR AGREEMENT
THAT YOU HAVE CHECKED. I DON’T BELIEVE AN ANNUAL
CHECK IS NECESSARY IF YOU 17 HAVE ANY CONCERNS.
IT WOULD BE GOOD PRACTICE TO GO AHEAD AND DOUBLECHECK IT.
THANKFULLY, THE NUMBER OF ORGANIZATIONS THAT HAVE BEEN
SUSPENDED FROM FEDERAL FUNDS IS REMARKABLY SMALL IN THE
SCHEME OF LIFE, BUT IT’S STILL A VERY IMPORTANT CHECK
TO DO. AND ELLEN, DO YOU HAVE A
DIFFERENT SENSE OR HOW OFTEN IT NEEDS TO HAPPEN?
MY UNDERSTANDING IS IT’S PRIOR TO THE CONTRACT BEING
AWARDED.>>SPECIFICALLY, UNIFORM
GRANT, I THINK IT’S RECOMMENDED THAT IT’S DONE
BEFORE. I THINK THE MAIN THING IS,
AGAIN, THE SUSPENSION AND DEBARMENT PROCESS IS NOT AN
EASY PROCESS TO UNDERGO, SO IF AN ORGANIZATION IS GOING
TO BE SUSPENDED OR DEBARRED, AND SO THE MAIN CONCERNING IS
TO DO IT BEFORE YOU GO INTO GRANT AWARD.
I THINK THIS IS SOMETHING KAREN CAN PROBABLY GO INTO
MORE DEPTH OF, WITH RISK ASSESSMENT.
IF THERE ISSUES WITH SUBRECIPIENT, IT’S NOT
NECESSARILY ON THE SUSPENSION OR DEBARMENT, BUT YOU ARE
HOPEFULLY GOING TO BE AWARE OF IT IF THEY ARE UNDERGOING
CERTAIN PROBLEMS THAT WOULD PUT THEM AT RISK OF NOT BEING
ABLE TO MANAGE THE FEDERAL FUNDS WELL.
SO THAT WOULD BE AN OBLIGATION THAT THE
SUBRECIPIENT WOULD NEED TO TAKE ON AND HOPEFULLY WORK
WITH THE — YOUR AGENCY WOULD BE NEEDING TO WORK WITH THE
SUBRECIPIENT TO WORK THROUGH 18 SOME OF THAT TO SEE IF THAT
COULD BE REMEDIED OR ADDRESSED SO THEY CAN
CONTINUE TO BE IN CONTRACT WITH YOU.
AGAIN, I THINK THE OVERALL GOAL OF THIS IS TO — THE
WHOLE CONCEPT OF SUBRECIPIENT MONITORING IS TO ENSURE THAT
THE SUBRECIPIENT THAT’S WORKING ON YOUR BEHALF IS
GOING TO BE MANAGING THE FEDERAL FUNDS APPROPRIATELY,
ALSO BEING ABLE TO SUCCEED IN BEING ABLE TO ACCOMPLISH THE
SPECIFIC DELIVERABLES THAT THEY ARE OBLIGATED FOR.
JUST AS YOU WOULD WITH YOUR FEDERAL AWARD.
>>SO KAREN, ANY OTHER THOUGHTS ABOUT THAT?
>>NO. I WILL TOUCH ON THIS DURING
THE RISK ASSESSMENT SECTION.>>GREAT.
OKAY. SO WE ARE GOING TO GO AHEAD
AND MOVE ON TO THE NEXT SLIDE.
OKAY, RISK ASSESSMENT. THE PURPOSE OF DOING A RISK
ASSESSMENT IS TO REDUCE WASTE, FRAUD AND ABUSE SO
THAT NONE OF THAT OCCURS, BECAUSE THAT IS ONE OF THE
THINGS THAT IS EMPHASIZED WHEN YOU GET A FEDERAL GRANT,
IS THAT THEY DO NOT WANT WASTE, FRAUD OR ABUSE ON
THEIR WATCH. AND THE HIGHER THAT YOU
ASSESS RISK ON AN ORGANIZATION, THE MORE LIKELY
THAT ONE OF THOSE ITEMS COULD OCCUR.
AND ACCORDING TO SECTION 200-205, YOU MUST ASSESS RISK
BEFORE YOU MAKE ANY SUBAWARD DECISIONS.
AND ONE OF THE THINGS THAT 19 SECTION 200-205 DOES, IS THAT
IT GIVES KIND OF A LIST OF ITEMS TO CONSIDER, ONE OF
WHICH IS FINANCIAL STABILITY. SO IN OTHER WORDS, IF YOU ARE
CONSIDERING PARTNERING WITH AN ORGANIZATION THAT HAS SOME
ISSUES AROUND FINANCIAL STABILITY, THAT IS SOMETHING
THAT YOU WOULD DEFINITELY WANT TO LOOK AT CLOSELY,
BECAUSE THE SUBRECIPIENT, YOU ARE RESPONSIBLE FOR THEM.
IN OTHER WORDS, IF THEY MAKE A MISSTEP OR THERE IS WASTE,
FRAUD AND ABUSE, YOU ARE GOING TO BE HELD RESPONSIBLE.
IF WE COULD GO ON TO THE NEXT SLIDE, PLEASE.
>>AND HERE’S SOME EXAMPLES OF RISK.
PERFORMANCE ISSUES. SO, IN OTHER WORDS, HAVE THEY
BEEN DINGED BY THEIR PROGRAM MANAGER BEFORE FOR NOT
PERFORMING AS THEY SHOULD. PRIOR AUDIT FINDINGS OR
MONITOR FINDINGS. SO IF THE ORGANIZATION DOES
GET A SINGLE AUDIT, ARE THERE ANY COST, ARE THERE ANY
SIGNIFICANT DEFICIENCIES. THAT’S THE KIND OF THING YOU
NEED TO LOOK AT. IS THE SUBRECIPIENT
EXPERIENCED OR INEXPERIENCED. SO IN OTHER WORDS, IF THIS IS
THEIR FIRST EXPERIENCE WITH FEDERAL FUNDING, YOU NEED TO
MONITOR THEM A BIT MORE CLOSELY BECAUSE THEY MAY NOT
KNOW THE INS AND OUTS OF FEDERAL FUNDING.
DOES THIS ORGANIZATION HAVE NEW AND OR INEXPERIENCED
STAFF. IN OTHER WORDS, IF THERE HAS
BEEN A BIG CHANGEOVER, ESPECIALLY LET’S SAY IN
SENIOR MANAGEMENT, YOU WANT 20 TO MAKE SURE THAT YOU HAVE
THE TIME AND THE CAPACITY YOURSELF TO BE ABLE TO WORK
WITH THEM TO MAKE SURE THAT THEY ARE COMPLIANT.
THE PROGRAM THAT YOU ARE GOING TO BE WORKING ON
TOGETHER, HOW COMPLEX IS IT. IF IT’S VERY COMPLEX, AGAIN,
THAT’S SOMETHING THAT YOU WANT TO TAKE INTO
CONSIDERATION WHEN YOU ARE ASSESSING RISK, BECAUSE IF
IT’S VERY COMPLEX, YOU WANT TO MAKE SURE THAT THE
ORGANIZATION THAT YOU ARE PARTNERING WITH CAN COMPLY
WITH EVERYTHING THAT NEEDS TO BE DONE ON THIS PROGRAM.
>>KAREN, THIS IS CINDY. JUST A QUICK NOTE ON THAT.
IF YOU ARE DOING A VERY SMALL SUBRECIPIENT CONTRACT WITH
PERHAPS A CULTURALLY-SPECIFIC OR NEW ORGANIZATION THAT’S
NEWLY FORMED, THEY MAY BE FAIRLY INEXPERIENCED WITH
FEDERAL GRANT MONEY, BUT THEY MAY HAVE AMAZING CONTENT THAT
YOU REALLY WANT ACCESS TO. THERE’S A COUPLE OF OPTIONS:
ONE IS TO HAVE THEM DO A VERY NARROWLY SCOPED CONTRACT
WHERE THEY ARE ESSENTIALLY FACILITATING REVIEWING
CURRICULUM, DOING SOMETHING THAT’S NARROWLY SCOPED SO
THAT THEY ARE NOT MAKING INDEPENDENT DECISIONS IN THE
GRANT MANAGEMENT SCHEME OF THINGS, AND THAT WAY YOU ARE
ABLE TO USE THEIR TALENT. ANOTHER IS TO DO A SMALLER
SUBRECIPIENT CONTRACT SO THAT THE RISK IS LESS FOR YOU, SO
IF THERE WAS SOMETHING, YOU KNOW, A SMALL AMOUNT OF MONEY
SPENT ON AN ITEM THAT’S NOT ALLOWED, YOU KNOW YOUR
ORGANIZATION CAN HANDLE THAT 21 IF IT WAS EVER CONSIDERED A
DISALLOWED COST. SO WE DON’T WANT ANYONE
THINKING THAT YOU CAN’T EVER CONTRACT OR USE A
SUBRECIPIENT THAT’S NEW, THAT’S CULTURALLY SPECIFIC
THAT PERHAPS DOESN’T HAVE THE ORG CAPACITY OF A LARGER,
MORE ESTABLISHED ORGANIZATION, BUT INSTEAD,
IT’S TO THINK ABOUT MAYBE HOW TO DO A SMALLER SCOPED
PROJECT WITH A NEWER ORGANIZATION AND HELP THEM
LEARN THE FEDERAL GOVERNMENT GRANT COMPLIANCE SORT OF
APPROACH, AND THEN I WILL TURN IT BACK OVER TO YOU,
KAREN.>>YEAH, THAT’S CORRECT.
WHAT WE WANT TO MAKE SURE IS THAT EVERYBODY SUCCEEDS.
SO, AGAIN, IF YOU ARE WORKING WITH SOMEBODY THAT MAY NOT
HAVE THE CAPACITY OR IS NEW AND INEXPERIENCED, SOMETHING
OF DUMPS, LET’S SAY, HALF THE PROGRAM ON THEM, START WITH
SOMETHING SMALL, YOU KNOW, HAVE A CONSULTING AGREEMENT
TO DO ONE PROJECT OR GIVE ONE TRAINING, AND WORK FROM THERE
SO THAT YOU CAN BUILD THEIR CAPACITY, ALSO, AND YOU KNOW,
AT THE END OF THE DAY, YOU’VE GOT AN AMAZING PARTNER THAT
YOU HAVE BEEN ABLE TO BRING ALONG AS OPPOSED TO, YOU
KNOW, OVERWHELMING A SMALLER ORGANIZATION AND HAVING THEM
FAIL. BECAUSE THAT’S DEFINITELY
SOMETHING WE DON’T WANT TO HAPPEN.
IF WE GO ON TO THE NEXT SLIDE, I CAN ADDRESS THAT A
LITTLE BIT MORE. SO AGAIN, AFTER YOU’VE DONE
THIS RISK ASSESSMENT, IF IT 22 LOOKS LIKE THE SUBRECIPIENT
NEEDS ASSISTANCE WITH CAPACITY AND HOW TO COMPLY
WITH GRANTS AND HOW TO DO THE PROGRESS REPORTS AND HOW TO,
YOU KNOW, FINANCIAL SEGREGATE THE FUNDS AND DO THE
ACCOUNTING CORRECTLY, IT IS PERMISSIBLE, AND THE UGG DOES
SAY THIS, THAT YOU CAN PROVIDE THEM WITH TRAINING
AND TECHNICAL ASSISTANCE. YOU JUST HAVE TO REMEMBER TO
WRITE THAT INTO THE GRANT SO THAT YOUR GRANT BUDGET HAS
THE MONEY IN THERE FOR DOING THIS.
SO, YOU KNOW IT MAY BE THAT YOU NEED TO GO UP AND VISIT
THEM, IT MAY BE THAT YOU NEED TO RECOMMEND SOME FINANCE
TRAINING, MAYBE I NEED TO GO AND TAKE THE OVW ONLINE
FINANCE COURSE TO GET THEM COMFORTABLE WITH HOW FEDERAL
FUNDS ARE SUPPOSED TO BE HANDLED.
UNFORTUNATELY, THE UGG DOES NOT GIVE US TEMPLATES OR
CHECKLISTS OR ANYTHING ELSE TO TELL US HOW WE ARE
SUPPOSED TO ASSESS RISK. THAT’S SOMETHING THAT WE KIND
OF HAVE TO COME UP WITH ON OUR OWN.
AND ON THE NEXT SLIDE, I PULLED A SIMPLE CHECKLIST
FROM A TRAINING I WENT TO. UNFORTUNATELY, I DO NOT FEEL
COMFORTABLE SHARING THIS ENTIRE CHECKLIST WITH
EVERYBODY. THIS WAS A TRAINING THAT I
HAD TO PAY FOR, AND THE INSTRUCTORS DID NOT GIVE US
PERMISSION TO SHARE THIS CHECKLIST FAR AND WIDE, SO I
JUST DID A SIMPLE SCREEN SHOT OF THE BEGINNING OF THIS
CHECKLIST JUST SO THAT YOU 23 COULD SEE WHAT ONE LOOKS
LIKE. AND I JUST WANT TO GO OVER A
COUPLE OF ITEMS IN THE CHECKLIST.
TO THE RIGHT OF THE RISK COLUMN, YOU WILL SEE CAUSE
FOR L, M AND H, THAT MEANS LOW, MEDIUM AND HIGH RISK,
AND IF YOU HAVE BEEN AN AUDITOR OR GET AN AUDIT, YOU
WILL RECOGNIZE SOME OF THIS, BECAUSE THIS IS SORT OF AN
AUDIT APPROACH, ASSESSING RISK.
SO IN OTHER WORDS, WHAT YOU WANT TO DO IS YOU WANT TO GET
TO KNOW THE ORGANIZATION THAT YOU ARE THINKING ABOUT
PARTNERING WITH SO THAT YOU CAN FILL OUT THIS CHECKLIST
AND FEEL COMFORTABLE WITH IT. NOW, THE FIRST LINE ITEM YOU
SEE UNDER GENERAL ASSESSMENT IS SUSPENSION AND DEBARMENT.
THAT’S THE FIRST THING YOU SHOULD DO.
AND IF IT TURNS OUT THAT THE ORGANIZATION IS ON THE
SUSPENSION OR DEBARMENT LIST, YOU DON’T HAVE TO GO ANY
FURTHER. YOU ARE ABSOLUTELY FORBIDDEN
FROM GIVING THEM ANY FEDERAL FUNDS.
SO YOU KIND OF WANT TO LIST THESE ITEMS IN A KIND OF
ORDER THAT MAKES SENSE. IN OTHER WORDS, IF THEY ARE
SUSPENDED OR DEBARRED, YOU KNOW THAT THEY CANNOT RECEIVE
ANY FEDERAL FUNDS. THEN YOU KIND OF GO DOWN YOUR
LIST, THE NUMBER GRANT GUIDANCE DOES HAVE ITEMS THAT
YOU HAVE TO GET FROM THEM, AND ELLEN WENT OVER THOSE IN
A PRIOR SLIDE. YOU KNOW, YOU DO HAVE TO LOOK
AT THEIR FINANCIAL 24 DOCUMENTATION, YOU HAVE TO
LOOK AT THEIR FINANCE FINANCIAL, AND YOU WANT TO
LOOK AT OTHER THINGS. FOR INSTANCE, THEIR
PERFORMANCE. DO THEY TURN THEIR PROGRESS
REPORTS IN ON TIME. DO THEY TURN THEIR FINANCIAL
REPORTS IN ON TIME. AND THOSE ARE ALL THINGS THAT
YOU AS THE PRIME RECIPIENT ARE JUSTIFIED IN ASKING
SOMEONE THAT YOU ARE CONSIDERING USING AS A
SUBRECIPIENT.>>KAREN —
>>I’M SORRY, I CAN’T SHARE THIS ENTIRE CHECKLIST WITH
YOU, BUT THIS WILL AT LEAST GET YOU STARTED.
AND FOR ME, IF I WAS WORKING WITH AN ORGANIZATION FOR THE
FIRST TIME, I WOULD PROBABLY ASSUME THAT IT’S A HIGH OR A
MEDIUM RISK. IT’S ONLY AS YOU GET TO WORK
WITH SOMEBODY AND YOU GET TO UNDERSTAND MORE OF HOW THEY
OPERATE THAT YOU COULD PROBABLY USE A LOW RISK
ASSESSMENT.>>KAREN, THERE WERE A COUPLE
OF QUESTIONS THAT CAME IN. ONE WAS LIKE HOW MANY PAGES
WAS THE ENTIRE CHECKLIST THAT YOU HAD RECEIVED IN YOUR
TRAINING PROGRAM?>>OH GOSH.
I DON’T REMEMBER. I THINK IT WAS TWO OR THREE.
THE TRAINING THEY WENT TO, A NUMBER OF THE ORGANIZATIONS
THAT WERE WITH ME IN THAT TRAINING WERE RATHER LARGE,
SO FOR PROBABLY THIS GROUP, I WOULD THINK THAT A COUPLE OF
PAGES AT THE MOST WOULD BE SUFFICIENT.
>>AND KAREN, THERE WAS 25 ANOTHER QUESTION THAT CAME IN
EARLIER, AND I THINK IT CAME IN A WHILE BACK, REGARDING
THE REQUESTED ITEMS THAT PEOPLE SHOULD HAVE BEFORE
THEY ENTER INTO A SUBAWARD, BUT SPECIFICALLY ABOUT THE
AUDIT, LIKE IF THE ORGANIZATION IS UNDER THE
THRESHOLD, LIKE A SMALL ORGANIZATION THAT HAS IS
UNDER THE $750,000 THRESHOLD THAT DOESN’T DO AN
INDEPENDENT AUDIT, WHAT SHOULD A GRANTEE DO BEFORE
ENTERING A SUBRECIPIENT AWARD WITH THEM?
>>WELL, I WOULD DEFINITELY GET A COPY OF THEIR FORM 990,
WHICH YOU CAN GET FROM THE ORGANIZATION ITSELF, OR YOU
CAN GET IT ON GOTSAR.ORG. I WOULD ALSO ASK FOR THEIR
INTERNAL FINANCIAL STATEMENTS, SPECIFICALLY.
I WOULD THINK THE ONES THEY SHARE WITH THEIR BOARD OF
DIRECTORS WOULD BE A GOOD SET OF FINANCIALS TO GET.
AND I WOULD PROBABLY SPEND SOME TIME JUST TALKING TO
THEIR FINANCE PERSON TO GET AN IDEA OF THEIR STRENGTHS
AND HOW THEY CLOSE THEIR MONTH AND THEIR FAMILIARITY
WITH FEDERAL GRANT ACCOUNTING.
>>AND KAREN, THIS IS CINDY. JUST A NOTE, TOO, THAT JUST
LIKE KAREN SAID, THAT IF YOU DO THE SUSPENSION DEBARMENT,
YOU ARE SORT OF OUT OF BOUNDS, AND YOU DON’T GO ANY
FURTHER, A SIMILAR SORT OF THING IS IF YOU HAVE PRIOR
EXPERIENCE HAVING ACTUALLY USED THE SAME ORGANIZATION AS
THE SUBRECIPIENT PREVIOUSLY AND THEY WERE TIMELY, THEY
GOT EVERYTHING IN ON TIME, 26 YOU REVIEWED ALL OF THOSE
DOCUMENTS AND EVERYTHING WAS GOOD, YOU KNOW THEY ARE
RECEIVING OTHER FEDERAL GRANTS, YOU ALSO CAN SLOW
DOWN YOUR RISK ASSESSMENT BECAUSE YOU’VE GOT PRIOR
POSITIVE FISCAL COMPLIANCE EXPERIENCE WITH THEM.
SO IT’S REALLY WHEN YOU ARE WORKING WITH AN UNKNOWN
ENTITY THAT YOU HAVE NOT USED AS A SEPARATE ENTITY BEFORE
THAT YOU NEED TO DO ADDITIONAL CHECKS, AND THAT
WE — WE WANT TO KNOW IF THINGS CHANGED, IF YOU HAVE A
SUBRECIPIENT AND YOU KNOW THEY’VE HAD FINANCE TURNOVER
AND UPHEAVAL AROUND FISCAL STUFF, BUT YOU DON’T HAVE TO
DO QUITE AS MANY LEVELS OF THESE ROWS OF A CHECKLIST IF
YOU KNOW THAT YOU’VE WORKED WITHIN LAST MONTH ON A
DIFFERENT GRANT AND THEY WERE STELLAR.
SO SOME OF THAT IS MAKING SURE THAT YOU ARE NOT GOING
OVERBOARD, BUT YOU ARE DOING ENOUGH TO BE COMPLIANT.
>>RIGHT. AND THE REASON THAT I CHOSE
THIS PARTICULAR CHECKLIST, KIND OF SCREEN SHOT TO SHARE,
WAS THAT NOT ONLY WERE THERE JUST COLUMNS FOR CHECKS
THINGS OFF, THERE ARE COLUMNS FOR WHY YOU ASSESS RISK AND
FOR ANY OTHER NOTES THAT YOU WANT TO ADD.
SO AS CINDY SAID, IF YOU USE THESE FOLKS AGAIN, YOU HAVE
ALREADY GOT A HISTORY WITH THEM, YOU’VE GOT
DOCUMENTATION, AND LET’S SAY YOU LEAVE THE ORGANIZATION,
WHOEVER COMES ALONG BEHIND YOU WILL HAVE ENOUGH
DOCUMENTATION THAT THEY DON’T 27 HAVE TO REINVENT THE WHEEL
AGAIN.>>KAREN, ANOTHER QUESTION
JUST CAME IN ABOUT CAN YOU OUTLINE SOME OF THE
DIFFERENCES, IF THE SUBRECIPIENT IS A FOR-PROFIT
ENTITY.>>I’M NOT SURE I WOULD DO IT
THAT MUCH DIFFERENT. YOU STILL NEED TO KNOW IF
THEY ARE SUSPENDED OR DEBARRED, YOU STILL WANT THEM
TO BE FINANCIALLY STABLE, YOU STILL WANT THEM TO HAVE THE
CAPACITY TO HANDLE FEDERAL FUNDING AND GET REPORTS IN ON
TIME AND HAVE GOOD FINANCIALS.
SOMETIMES, FOR-PROFIT ENTITIES WILL BE MORE LIKELY
TO NOT NECESSARILY GET AN AUDIT, BUT TO GET A REVIEW OR
A COMPILATION FROM AN OUTSIDE ACCOUNTANT, SO YOU COULD
ALWAYS ASK FOR THOSE REPORTS.>>THIS IS CINDY, I THINK ONE
MORE THING I WOULD DO WITH A FOR-PROFIT IS MAKE SURE THEY
UNDERSTAND LIMITATIONS ON FEDERAL FUNDS, BUT I WOULD
ALSO DO THAT WITH A NONPROFIT THAT’S NEVER RECEIVED FEDERAL
GRANT FUNDS, IF THEY ARE GETTING PRIMARILY DONATION IT
IS AND PRIVATE GRANTS, THEY MAY BE MORE COMFORTABLE WITH
THINGS LIKE PAYING A FLIGHT CHANGE FEE OUT OF THEIR
PRIVATE GRANT MONEY OR FOR-PROFIT WOULD CONSIDER
THAT THE COST OF DOING BUSINESS BUT YOU CAN’T CHARGE
A FLIGHT CHANGE FEE BECAUSE IT’S CONSIDERED A PENALTY TO
A FEDERAL GRANT UNLESS IT’S APPROVED BY YOUR FEDERAL
GRANT MANAGER. SO THOSE TYPES OF THINGS, YOU
WOULD WANT TO MAKE SURE YOUR 28 FOR-PROFIT RECIPIENT
UNDERSTANDS OR A NONPROFIT THAT’S NOT DONE A LOT WITH
FEDERAL GRANT DOLLARS BECAUSE CHANGE FEES FOR A FLIGHT ARE
NOT COVERED. THEY ARE KIND OF NORMAL, BUT GOVERNMENT
FUNDING DOESN’T ALLOW IT WITHOUT PERMISSION.
>>RIGHT, AND IF IT WERE A FOR-PROFIT ENTITY, YOU COULD,
AS PART OF YOUR CONTRACT WITH THEM, REQUIRE THAT THEIR
FINANCE PERSON GO THROUGH THE OVW ONLINE FINANCE TRAINING
AND PROVIDE YOU WITH A CERTIFICATE.
THERE IS NOTHING WRONG WITH DOING THAT, YOU KNOW, BECAUSE
YOU ARE THE ONE THAT HAS TO BE COMFORTABLE WITH THE WORK
THIS THEY DO. SO JUST LIKE YOUR FEDERAL
GRANT DOCUMENT WILL SOMETIMES HAVE SPECIAL CONDITIONS, YOU
ARE ALLOWED TO PUT SPECIAL CONDITIONS IN THE CONTRACT
THAT YOU HAVE WITH THE SUBRECIPIENT.
>>OKAY, WE HAVE ANOTHER POLLING QUESTION.
SO ONCE AGAIN, THE ANSWER BOX FOR THIS IS ABOVE THE CHAT
BOX, SO THE QUESTION IS, AS PART OF THE PREAWARD
REQUIREMENTS, YOU SHOULD OBTAIN AND REVIEW THE
FOLLOWING DOCUMENTS FROM THE POTENTIAL SUBRECIPIENT: A,
MOST RECENT FINANCIAL MANAGEMENT POLICY MANUAL, B,
MOST RECENT FINANCIAL AUDIT AND THEIR TAX RETURNS, C,
BOARD MEETING MINUTES ADDRESSING THE AUDIT AND OR
TAX RETURNS, OR D, ALL OF THE ABOVE.
>>OKAY, KAREN, WE HAVE MANY FOLKS THAT HAVE — WE’VE BEEN
GOING BACK AND FORTH ON THIS 29 SLIDE BUT FOLKS HAVE BEEN
RESPONDING AND THEY ARE CONTINUING TO RESPOND.
IT LOOKS LIKE THERE’S OVERWHELMINGLY — THE
MAJORITY OF FOLKS HAVE RESPONDED, THEY ARE STILL
CONTINUING TO, IT LOOKS LIKE IT’S 100 PERCENT ARE
ANSWERING D.>>D, YES, WHICH D IS THE
CORRECT ANSWER.>>THIS IS CINDY.
OUR JOBS ARE DONE, WE CAN ALL GO HOME NOW!
>>THAT’S RIGHT. WE ARE GOING TO MOVE TO THE
NEXT POLLING QUESTION.>>AND THIS ONE IS MINE,
CINDY, AND SO IF A POTENTIAL SUBRECIPIENT IS ON THE
FEDERAL SUSPENSION OR DEBARMENT LIST, YOUR AGENCY
CAN ENTER INTO A SUBAWARD CONTRACT WITH THEM, A, TRUE,
B, FALSE.>>AND FOLKS ARE RESPONDING.
WE HAVE ONE PERSON THAT CLICKED A, TRUE, MAJORITY OF
PEOPLE ARE RESPONDING B, FALSE.
>>I THINK WE CAN PROBABLY MOVE TO THE NEXT SLIDE.
>>UH-HUH.>>THE ANSWER IS B, FALSE.
>>OKAY. SO NOW WE’RE GOING TO GO
AHEAD AND TALK A LITTLE ABOUT SOME OF THE ELEMENTS THAT
NEED TO BE INCLUDED IN THE SUBRECIPIENT CONTRACT.
AGAIN, THIS IS ALL INFORMATION THAT’S COME OUT
OF THE UNIFORM GRANT GUIDANCE.
HERE’S A QUICK CHECKLIST OF THESE ARE THE MUST INCLUDES,
IN OTHER WORDS, THEY ARE REQUIRED ELEMENTS IN
SUBRECIPIENT CONTRACTS, AND 30 SO JUST QUICKLY TO GO OVER
THEM, THE FIRST THING IS YOU OBVIOUSLY HAVE TO HAVE THE
SUBRECIPIENT’S NAME, THE OTHER KEY PIECE, THEY NEED TO
HAVE THE DUN’S NUMBER JUST LIKE WHEN YOUR AGENCY APPLIED
FOR ANY FEDERAL GRANT APPLICATIONS THAT YOU HAVE TO
HAVE A DUNS NUMBER IN ORDER TO PROCEED.
THAT’S IMPORTANT IF YOUR SUBRECIPIENT DOESN’T HAVE
THAT, THAT PROCESS IS FAIRLY STRAIGHTFORWARD, YOU CAN ALSO
CONTACT ME OFF LINE, AND I CAN KIND OF GIVE YOU THE
CONTACT AND INFORMATION ON HOW THEY CAN GO AHEAD AND
APPLY FOR A DUN’S NUMBER. THE OTHER THING THAT THE
CONTRACTS MUST INCLUDE IS THE FEDERAL GRANT AWARD NUMBER
THAT YOU HAVE FOR THE OVERALL GRANT, THE FEDERAL GRANT
AWARD, THE AWARD DATE AND PROJECT DESCRIPTION.
THAT’S LISTED USUALLY ON THE COVER PAGE OF THE GRANT
AWARD. THE PERIOD OF THE
SUBRECIPIENT’S AWARD. SAY FOR EXAMPLE IF YOUR GRANT
AWARD IS A TWO-YEAR GRANT AWARD FROM OCTOBER OF 2016,
THAT GOES THROUGH 2018, YOU NEED TO — YOUR GRANT, YOUR
SUBRECIPIENT GRANT AWARD COULD BE IF A SHORTER TIME
PERIOD SO YOU NEED TO BE SPECIFIC IN LISTING THE
PERIOD OF THE SUBRECIPIENT AWARD.
THE OTHER THING THAT’S REQUIRED IS THE AMOUNT OF THE
ENTIRE FEDERAL AWARD, AND THE AMOUNT TO THE SUBRECIPIENT.
SO THE EXAMPLE WOULD BE IF YOUR FEDERAL GRANT IS
$200,000, AND YOU ARE ONLY 31 PROVIDING A $10,000 AWARD TO
THE SUBRECIPIENT, THOSE TWO AMOUNTS NEED TO BE LISTED IN
THERE. YOU ALSO NEED TO LIST THE
AGENCY THAT IS ISSUING THE GRANT AWARD, SUCH AS OVW, AND
THE CONTACT INFORMATION FOR THE CONTACT PERSON, OVW, FOR
YOUR GRANT AWARD. YOU ALSO NEED TO INCLUDE THE
CFDA NUMBER. THAT’S THE CFDA NUMBER FOR
THE GRANT SOLICITATION THAT YOU APPLIED UNDER.
LIKE IF YOU APPLIED UNDER THE LEGAL ASSISTANT TO VICTIMS
GRANT YOU WOULD PULL THE CFDA NUMBER.
TYPICALLY AUDITORS WOULD REQUEST THAT AS YOU ARE DOING
THE AUDIT BUT IF NOT YOU NEED TO PULL THAT CFDA NUMBER FROM
THE GRANT SOLICITATION. YOU ALSO NEED TO HAVE
INCLUDED IN THERE AS YOU NORMALLY WOULD FOR ANY KIND
OF AGREEMENT WITH ANYBODY THAT YOU ARE DEALING WITH,
YOU WOULD WANT TO HAVE THE SPECIFIC GRANT DELIVERABLES
OR REQUIREMENTS THAT YOU HAVE WITH THE SUBRECIPIENT, WHEN
THEY ARE DOING TO HELP WITH YOUR SPECIFIC GRANT OR
CARRYING OUT THE DELIVERABLES TO MEET THE OBJECTIVES OF
YOUR OVERALL GRANT. YOU WANT TO HAVE THOSE ITEMS
IN THERE. YOU ALSO WANT TO HAVE
INFORMATION ABOUT WHAT THE PROCESS IS FOR INVOICING AND
THE BACKUP DOCUMENTATION THAT NEEDS TO BE MAINTAINED FOR
FEDERAL FUNDS, AND WHAT NEEDS TO BE SUBMITTED FOR
REIMBURSEMENT. THOSE ARE THE GENERAL
CHECKLIST OF KEY ITEMS THAT 32 MUST BE INCLUDED IN YOUR
CONTRACT. WE ALSO HAVE A LIST OF ITEMS
THAT WOULD BE CONSIDERED BEST PRACTICE OR IT ITEMS THAT WE
RECOMMEND THAT YOU SHOULD INCLUDE IN YOUR CONTRACT AS
WELL, INFORMATION ABOUT PROGRESS REPORTS, AS YOU ARE
REQUIRED TO SUBMIT PROGRESS REPORTS TO OVW FOR YOUR
GRANTS YOU PROBABLY WANT TO MAKE SURE YOU HAVE THE
SPECIFIC INFORMATION AND STATISTICS OR INFORMATION
THAT YOU NEED FROM THE SUBRECIPIENT FOR YOU TO BE
ABLE TO SUCCESSFULLY COMPLETE YOUR PROGRESS REPORTS, LIKE
THE ITEMS THAT THEY WOULD BE RESPONSIBLE FOR.
SO WHAT NEEDS REPORTED AND THE DUE DATE.
SOME OF THE INFORMATION THAT YOU MIGHT BE GETTING OR
GETTING TRAINING ON FROM MSKE, IF IT’S RELEVANT TO
WHAT SUBRECIPIENT IS DOING YOU MAY WANT TO PASS ON SOME
OF THAT INFORMATION AND PROVIDE SOME OF THAT TRAINING
FOR THE SUBRECIPIENT. THE OTHER THING THAT SHOULD
BE INCLUDED IS THAT YOUR STUFF IN THE CONTRACT, YOU
SHOULD BE NOTIFIED OF ANY CHANGES IN KEY STAFF, EVEN
THOUGH YOU MAY BE MEETING REGULARLY WITH THE
SUBRECIPIENT. IT’S JUST IMPORTANT TO HAVE
THAT. WE STRONGLY RECOMMEND THAT
THAT BE INCLUDED IN THE ACTUAL CONTRACT AND THE
PROCESS FOR THAT, AND THAT ALSO THE SUBRECIPIENT CAN
MAKE A CONFLICT OF INTEREST POLICY FOR THEIR BOARD OF
DIRECTORS AND KEY STAFF. 33 THAT’S USUALLY A GOOD
PRACTICE TO HAVE. AGAIN, IT’S CONSISTENT WITH
WHAT MAY BE NOTED IN THEIR 990.
BUT AGAIN, IT WOULD BE IMPORTANT TO ENSURE THEY HAVE
THAT PRACTICE IN PLACE. THAT IS USUALLY A KEY ISSUE
THAT COMES UP IN ANY FEDERAL AUDIT OR ANY CONCERNS OR
COMPLIANCE ISSUES. THEY USUALLY STEM FROM A
CONFLICT OF INTEREST ISSUE IN MANY CASES.
>>THE OTHER THING THAT IS ALSO — THAT WE ALSO STRONGLY
RECOMMEND IS HAVING, ENSURING THE SUBRECIPIENT MAINTAIN A
WHISTLEBLOWER POLICY TO BE REVIEWED AND SIGNED BY STAFF.
IF YOU NEED INFORMATION ABOUT EITHER OF THESE ITEMS, I CAN
CERTAINLY SEND YOU COPIES, SO FEEL FREE, OR SAMPLE
TEMPLATES, THE CONFLICT OF INTEREST POLICIES TO REVIEW
OR PASS ON TO A SUBRECIPIENT AND FINALLY, THE LAST ITEM
THAT WE RECOMMEND YOU SHOULD INCLUDE IN A A SUBRECIPIENT
CONTRACT IS TERMINATION CLAUSE FOR NONPERFORMANCE OR
NONCOMPLIANCE IN THE CONTRACT.
IT’S ALWAYS IMPORTANT IN ANY KIND OF CONTRACTING PROCESS
THAT THERE SHOULD BE A TERMINATION PROCESS SHOULD
YOU HAVE CONCERNS ABOUT NONPERFORMANCE AND
NONCOMPLIANCE AND AN OPPORTUNITY IF THE
SUBRECIPIENT WANTS TO PULL OUT OF AN AGREEMENT THAT
THERE SHOULD BE A CONTRACT FOR BOTH PARTIES TO TERMINATE
THE CONTRACT IF NEEDED. THOSE ARE GENERAL ITEMS THAT
WE STRONGLY RECOMMEND BE 34 INCLUDED IN THE CONTRACT.
>>ELLEN, I’VE GOT ONE MORE ADDITION, THEN A QUESTION.
>>SURE.>>THE ONE THING THAT I HAVE
STARTED DOING WITH THE PERIOD OF THE CONTRACT, WHERE YOU
PUT THE START AND END DATES, HAVING OF HAVING TO AMEND OR
EXTEND THE CONTRACT, IF WE DO A NO COST EXTENSION, WHICH IS
COMMON IF THE AWARD STARTS LATE BECAUSE IT TAKES A WHILE
FOR THE BUDGET TO CLEAR AND YOU START YOUR GRANT
ACTIVITIES THREE MONTHS IN, WHAT I’VE TYPICALLY DONE IS
LISTED THE START AND END DATE OF THE AWARD, AND THEN
INSERTED A NOTE THAT IF THE AWARD IS GIVEN A NO COST
EXTENSION TO CONTINUE THE GRANT ACTIVITIES, THEN THIS
CONTRACT OR MOU IS AUTOMATICALLY EXTEND TO MATCH
THE AWARD END DATE SO WE DON’T HAVE TO GO BACK AND DO
AN AMENDMENT, BUT THEN ONE OF THE QUESTIONS THAT CAME IN
WAS ABOUT WHAT IF SOMEBODY HAS DONE AN MOU BUT NOT
EVERYTHING IS IN IT, DO WE NEED TO REDO IT.
BASICALLY, CONTRACTS, EMAILS, MOUS, THEY ARE LEGALLY
BINDING, SO WHAT YOU MIGHT WANT TO DO IS SORT OF AN
ADDENDUM, BUT JUST MAKE SURE THAT IT DOESN’T OVERRIDE THE
EXISTING MOU THAT IT SUPPLEMENTS SO THAT YOU ARE
NOT — IF YOU ARE GOING TO ADD TO IT.
BUT IF YOU HAVE ALREADY COVERED THIS IN AN MOU AND
FEEL CONFIDENT THAT’S WORKABLE BUT YOU’VE GOT A FEW
ADDITIONAL ITEMS YOU COULD DO AN ADDENDUM AND COVER THOSE
ADDITIONAL ISSUES AND NOTE 35 THIS SUPPLEMENTS AND ADDS TO
AN EXISTING MOU.>>RIGHT.
BASICALLY, YOU HAVE LANGUAGE IN THERE SAYING THAT ALL
OTHER ELEMENTS OF THE MOU ARE IN PLACE AND ARE BINDING AND
THAT THIS IS AN ADDENDUM JUST INCLUDING THE ADDITIONAL
ITEMS. I THINK THOSE ARE EXCELLENT
SUGGESTIONS.>>AND E-MAIL ALSO CONSIDERED
A LEGALLY BINDING DOCUMENT. SO IF YOU JUST NEED TO ADD
ONE ITEM BECAUSE THAT’S ALL THAT’S MISSING, YOU COULD
EVEN DO AN E-MAIL AND SAY THIS E-MAIL AMENDS AND
ADDENDS AND ADDS THIS ELEMENT TO AN EXISTING MOU OR
CONTRACT. THOSE PARTIES CONFIRM IT BACK
AND FORTH, AND YOU CAN BOTH PRINT IT.
SO IT DOESN’T HAVE TO BE BURDENSOME.
THE POINT IS WE WANT TO MAKE SURE THE BEST PRACTICES THAT
ELLEN COVERED, AND THOSE ISSUES ARE COVERED, SO THAT
EVERYBODY UNDERSTANDS THE ROLES AND IS CLEAR ON THAT.
BUT WHETHER IT’S, YOU KNOW — YOU DON’T HAVE TO HAVE
WHEREAS IN YOUR CONTRACT TO MAKE IT BINDING.
>>RIGHT.>>AND SO I’M WONDERING IF
THERE’S ANOTHER QUESTION. WAS THERE ANOTHER ONE THAT CAME
IN?>>THERE WAS A QUESTION ABOUT
WHAT ARE RECOMMENDED ITEMS. ON THE SLIDE THAT’S BEFORE
YOU, THIS SLIDE IS THE ITEMS THAT ARE RECOMMENDED THAT
NEED — THAT WE RECOMMEND THAT SHOULD BE INCLUDED IN
THE CONTRACT. 36 THE PRIOR SLIDE IS WHAT ARE
THE REQUIRED ITEMS UNDER THE UNIFORM GRANT GUIDANCE.
AND SO WE WILL ALSO MAKE THESE HANDOUTS OR THE POWER
POINT PRESENTATION AVAILABLE AND BE SENDING THAT TO YOU
FOLLOWING TODAY’S PRESENTATION.
>>SO I’M GOING TO MOVE ON TO THE NEXT SLIDE, WHICH IS THE
POLLING QUESTION. AND SPECIFICALLY, CINDY, I
THINK YOU WERE GOING TO COVER THE POLLING QUESTION.
>>QUESTIONS. AND SO FOR THIS ONE, WHICH OF
THE FOLLOWING MUST BE INCLUDED IN THE SUBRECIPIENT
CONTRACT? A, SUBRECIPIENT NAME AND
DUN’S NUMBER, B, FEDERAL AGENCY ISSUING THE GRANT
AWARD, I.E., OVW, AND CFDA NUMBER, C, FEDERAL GRANT
AWARD NUMBER, AWARD DATES AND PROJECT DESCRIPTION, D, ALL
OF THE ABOVE.>>AND WE ARE GETTING A LOT
OF DS IN THE CHAT BOX. SO I THINK WE HAVE COVERED
THIS WELL AND PROBABLY CAN WRAP AND GO TO THE NEXT
SLIDE. AND IT IS D, ALL OF THE
ABOVE.>>SO KAREN, I THINK YOU ARE
COVERING THE MONITORING REQUIREMENTS.
>>YES, I AM.>>OKAY.
>>AS PART OF HAVING A SUBRECIPIENT, IS IF YOU HAVE
TO MONITOR THEM, ON A REGULAR BASIS, AND DEPENDING ON THE
SIZE OF THE AWARD, THE COMPLEXITY, AND YOU KNOW, ALL
THOSE OTHER ELEMENTS THAT WE TALKED ABOUT, YOU MAY HAVE
MONTHLY MEETINGS TO DISCUSS 37 THE PROGRAM ACTIVITIES,
DELIVERABLES, AND PERFORMANCE, AND WHEN WE SAY
MEETINGS, WE DON’T MEAN NECESSARILY IN-PERSON
MEETINGS. YOU CAN DO THIS BY PHONE, YOU
CAN DO THIS BY SKYPE, DEPENDING.
YOU CAN ALSO DO IT BY E-MAIL. AND AS PART OF THE CONTRACT,
YOU SHOULD PROBABLY PUT IN THERE HOW YOU EXPECT TO BE
INVOICED. DO YOU WANT THE SUBRECIPIENT
TO INVOICE YOU ON A MONTHLY BASIS OR A QUARTERLY BASIS.
AND THAT’S SOMETHING YOU SHOULD PROBABLY TALK ABOUT
WITH YOUR SUBRECIPIENT, BECAUSE IF THEY ARE A SMALL
ORGANIZATION, THEY MAY NOT BE ABLE TO FLOAT THE CASH FOR AN
ENTIRE QUARTER. SO THEY MAY WANT MONTHLY
INVOICING, WHICH IS FINE, AND YOU NEED TO GO OVER WHAT
NEEDS TO BE INCLUDED AS PART OF THAT INVOICE.
YOU KNOW, IF SOMEONE IS DOING LET’S SAY A TRAINING CLASS,
AND THEY HAVE TO TRAVEL TO DO THIS TRAINING, WELL, YES, YOU
ARE GOING TO WANT A COPY OF THEIR PLANE TICKET, A COPY OF
THE HOTEL BILL, AND THINGS LIKE THAT.
THE OTHER THING THAT YOU WANT TO TALK ABOUT WHEN YOU ARE
DOING YOUR MONITORING VISITS, PHONE CALLS, IS TO FIND OUT
IF THERE HAVE BEEN ANY, YOU KNOW, STAFF CHANGES, AND TO
GET THOSE NEW NAMES AND CONTACT INFORMATION, AND YOU
WANT TO TALK ABOUT PROGRESS REPORTS.
WE ALL KNOW HOW QUICKLY PROGRESS REPORTS ARE DUE AT
THE END OF A QUARTER FOR 38 FINANCE, AND AT THE END OF A
SIX MONTH PERIOD FOR THE PROGRAM REPORTS, SO THAT YOU
WANT TO MAKE SURE THAT YOUR SUBRECIPIENT KNOWS THAT THEY
HAVE TO GET YOU THAT INFORMATION BY A CERTAIN DATE
SO THAT YOU CAN INCORPORATE ALL THAT INFORMATION INTO
YOUR REPORTS. AND AGAIN, DOCUMENT ANY OF
YOUR MEETINGS. YOU KNOW, IF YOU ARE DOING IT
BY PHONE, PLEASE TAKE NOTES, AND WHAT I WOULD DO, I WOULD
SEND THE NOTES TO THE PERSON YOU ARE DISCUSSING WITH, AND
SAY, YOU KNOW, PLEASE VERIFY THAT THIS IS YOUR
UNDERSTANDING OF THE, QUOTE UNQUOTE, MEETING THAT WE JUST
HAD. AND ON AN ANNUAL BASIS, YOU
WANT TO MAKE SURE THAT YOU HAVE GOT THE ANNUAL AUDIT
FROM YOUR SUBRECIPIENT WITH THE MANAGEMENT LETTER IF YOU
HAVE A SUB THAT MEETS THE AUDIT THRESHOLD.
YOU WANT TO GET A COPY OF THEIR FINANCE POLICES AND
PROCEDURES IF THEY UPDATE IT ON AN ANNUAL BASIS.
YOU WANT COPIES OF THEIR TAX RETURNS.
YOU WANT COPIES OF THEIR BOARD OR COMMITTEE MEETING
MINUTES THAT ADDRESS THE REVIEW OF THEIR ANNUAL AUDIT,
ANY OF THE FINANCE POLICY UPDATES OR TAX RETURNS, AND
IF THERE’S BEEN ANY OTHER KIND OF DISCUSSION THAT WILL
IMPACT THE FEDERAL GRANT AND THEIR PROGRESS ON IT.
YOU WANT TO ALSO GET THOSE MEETING MINUTES.
>>AND AGAIN, I CAN’T STRESS THIS ENOUGH, YOU ARE
RESPONSIBLE FOR THIS SUB. 39 THEY ARE KIND OF STEPPING
INTO YOUR SHOES. SO THESE MONITORING VISITS
AND THE DOCUMENTATION, IT MAY SEEM LIKE IT’S KIND OF
BURDENSOME, BUT IT IS REQUIRED, AND IT WILL KEEP
EVERYBODY OUT OF TROUBLE, AND IT WILL KEEP EVERYBODY
HOPEFULLY SUCCEEDING, AND YOU KNOW, BECAUSE IF YOU ARE
DOING THESE KIND OF REGULAR MONITORING MEETINGS, IF THERE
IS A POTENTIAL PROBLEM YOU WILL BE ABLE TO NIP IT IN THE
BUD AS OPPOSED TO WAITING FOR A 12 MONTH PERIOD AND ALL OF
THE SUDDEN YOU GET A COPY OF THEIR AUDIT AND THERE’S A
WHOLE LOT OF AUDIT FINDINGS AND QUESTIONED COSTS.
WELL, IF YOU CAN WORK WITH YOUR SUBRECIPIENT BEFORE IT
GETS TO THAT POINT, THEN EVERYBODY WILL SUCCEED AND
YOU DON’T HAVE TO RUN THE RISK OF YOU OR YOUR
SUBRECIPIENT HAVING TO UNDERGO AN OIG AUDIT OR
ANYTHING ELSE THAT PAINFUL.>>NOW, AS TO WHETHER OR NOT
TO DO ON SITE OR DESK MONITORING, IT’S NOT
INQUIRED. AGAIN, THIS DECISION IS BASED
ON RISK ASSESSMENT AND HOW THE PROGRESS MONITORING IS
GOING. I WOULD ALSO TAKE INTO
ACCOUNT THE DOLLAR AMOUNT OF THE AWARD.
SO IN OTHER WORDS, YOU KNOW, IF YOU HAVE A SUBRECIPIENT
AWARD THAT IS $10,000, I WOULD PROBABLY NOT FLY OUT TO
THEIR LOCATION AND DO ANY KIND OF ON SITE MONITORING,
BECAUSE THAT’S GOING TO BE A LOT OF MONEY FOR, YOU KNOW, A
SMALL AMOUNT. 40 BUT IF YOU HAVE A — LET’S
SAY A MULTI-MILLION-DOLLAR AWARD, AND YOU HAVE AWARDED
THAT MONEY TO A SUBRECIPIENT AND LET’S SAY IT’S A THIRD TO
A HALF, THEN YES, I WOULD DO A WHOLE LOT MORE MONITORING,
AND THERE IS A GOOD CHANCE THAT I WOULD BE VISITING
THEM, ESPECIALLY IF YOU HAVEN’T WORKED WITH THEM MUCH
BEFORE. AND AGAIN, GRANT FUNDS CAN
PAY FOR THIS TYPE OF MONITORING.
IT’S ONE OF THOSE THINGS THAT YOU JUST HAVE TO WRITE INTO
YOUR GRANT BUDGETS. YOU CAN ALSO ARRANGE FOR
AGREED UPON PROCEDURES TO BE DONE BY ANOTHER ORGANIZATION.
LET’S SAY THAT YOU THINK THAT THIS PARTICULAR SUBRECIPIENT
COULD BENEFIT FROM SOME HELP FROM AN ACCOUNTING FIRM.
WELL, YOU CAN HAVE A CONTRACT WITH A FIRM TO GO OUT AND DO
SOME AGREED UPON PROCEDURES. SO LET’S SAY YOU WANT TO MAKE
SURE THAT THIS SUBRECIPIENT HAS A GOOD SET OF FINANCE
POLICES AND PROCEDURES, AND IS DOING WHAT THEY ARE
SUPPOSED TO BE DOING AS FAR AS THEIR ACCOUNTING SYSTEM
AND TRACKING FEDERAL FUNDS. WELL, YOU CAN HIRE SOMEBODY
TO DO THAT FOR YOU. AND I PUT THE SECTION NUMBER
IN THERE, 200.425C, WHICH GIVES GUIDANCE ON HOW TO DO
THIS.>>KAREN?
WE’VE GOT ONE QUESTION. THIS IS CINDY.
AND IT ACTUALLY IS SORT OF A TWO-FER, BECAUSE I HAD A
POINT I WAS GOING TO MAKE. YET IS WHAT BUDGET LINE ITEM
SHOULD WE PUT GRANT 41 MONITORING COSTS IN, AND IT
WOULD MATCH YOUR NORMAL GRANT COSTS.
SO IF IT’S GOING TO BE STAFF TRAVEL BECAUSE YOU EXPECT TO
FLY, DRIVE, YOU KNOW, PAID-FOR MILEAGE TO VISIT
YOUR GRANT PARTNER, YOUR SUBRECIPIENT, THEN IT WOULD
BE IN THE STAFF TRAVEL AND YOU WOULD PROBABLY LIST A
HANDFUL OF PROGRAMMATIC TRIPS AND THEN YOU MIGHT HAVE A
GRANT MONITORING TRIP THAT YOU LIST.
THE OTHER THING TO THINK ABOUT IS DEPENDING UPON YOUR
WORK WITH THAT GRANT PARTNER, THAT SUBRECIPIENT, YOU MIGHT
ALREADY BE PLANNING TO MEET IN PERSON TO GO OVER GRANT
ACTIVITIES AND PROJECT ACTIVITIES AND COULD PUT
ASIDE A HALF DAY OR EVEN A COUPLE OF HOURS TO
SPOT-CHECK, FOR EXAMPLE, WITH NNEDV, WE HAVE A VERY LARGE
GRANT PARTNER WHERE WE ARE GOING TO BE GETTING MANY
DIFFERENT PEOPLE FROM THE ORGANIZATION TO BE BILLING
TIME TO THIS PARTICULAR INITIATIVE.
PERSONALLY, I DON’T WANT TO SEE EVERY SINGLE TIME SHEET,
BUT I DO NEED TO DOUBLECHECK THE REPORTING SYSTEM WHERE
THEY PULL OUT THIS PERSON, THE NUMBER OF HOURS AND
ACTIVITIES, THEY CAN PULL IT OUT FOR THE TIME SYSTEM.
THE IMPORTANT THING FOR ME, WHEN I DO AN IN-PERSON
PLANNING TO TALK ABOUT PROGRAMMATIC WORK, I’M GOING
TO ASK FOR ONE PAY PERIOD, ONE TIME SHEET PERIOD OF THE
ACTUAL TIME SHEETS TO DOUBLECHECK THEM AND MATCH
THEM UP TO THE REPORT SO THAT 42 I FEEL CONFIDENT THAT THE
REPORTS WE ARE GETTING EVERY TIME WITH THEIR INVOICE MATCH
THEIR ACTUAL TIME SHEETS. SO IT DOESN’T HAVE TO BE
FINANCIALLY BURDENSOME, ESPECIALLY IF YOU ARE ALREADY
DOING REGULAR MEETINGS WITH THAT GRANT PARTNER.
BUT WHAT YOU WANT TO DO IS KNOW THAT WHATEVER INVOICES
AND PAPERWORK YOU ARE GETTING FROM THEM, YOU CAN STAND
BEHIND IT, THEY CAN STAND BEHIND IT, AND ESPECIALLY
WITH DESK AUDIT THINGS, WHERE THEY ARE SENDING YOU POLICES
AND PROCEDURES AND YOU ARE CHECKING THEM REGULARLY ABOUT
HOW THINGS ARE GOING — IT DOESN’T HAVE TO BE A HUGE
HULLABALOO WHERE IF YOU JUST HAVE A MEETING AND TYPE UP
SHORTS NOTES FROM WHAT YOU DISCUSSED AND SAID NOTES FROM
OUR MEETING AND SEND IT OFF, IF THEY DISAGREE AND SAY NO,
I ACTUALLY THINK WE FORGOT TO INCLUDE THIS TOPIC, YOU WILL
HAVE A BACK AND FORTH. AGAIN, YOU ARE SHOWING DUE
DILIGENCE THAT YOU ARE HAVING REGULAR CONTACT.
>>I AGREE. AGAIN, LIKE A LOT OF WHAT WE
TALKED ABOUT, THIS IS A JUDGMENT CALL AS TO WHETHER
OR NOT YOU THINK YOU HAVE TO DO ON SITE MONITORING.
AS THE PRIME RECIPIENT YOU ARE NOT PROHIBITED FROM
ASKING FOR COPIES OF THEIR TIME SHEETS OR ASKING HOW
THEY TRACK THEIR TIME, HOW THEY ACCOUNT FOR IT IN THEIR
ACCOUNTING SYSTEM, BECAUSE YOU DO WANT TO MAKE SURE THAT
THINGS ARE BEING DONE CORRECTLY, AND IF THERE IS AN
ISSUE, YOU WANT TO BE ABLE TO 43 HELP THEM DO THINGS BETTER.
IT’S NOT NECESSARILY — I DON’T MEAN ALL THIS TO BE
PUNITIVE. I WANT THIS TO BE SEEN AS THE
OPPORTUNITY TO HELP ANOTHER AGENCY SUCCEED.
>>KAREN, THERE’S ANOTHER QUESTION THAT CAME IN
SPECIFICALLY, IDENTITIES SUCH AS LOCAL SCHOOL DISTRICTS AND
LAW ENFORCEMENT AGENCIES, ARE THEY CONSIDERED SUBRECIPIENTS
SUBJECT TO THESE PROVISIONS? THEY HAVE DIFFERENT FINANCIAL
REQUIREMENTS THAN NONPROFIT? YOU CAN SPEAK TO THAT A
LITTLE BIT?>>I GUESS IT WOULD BE YOU
WOULD HAVE TO GO THROUGH THE ANALYSIS TO SEE IF THEY ARE
CONSIDERED SUBRECIPIENTS, AND I DON’T THINK IT MATTERS WHAT
TYPE OF ENTITY THEY ARE. IF THEY ARE SUBRECIPIENTS,
THEY ARE GOING TO BE SUBJECT TO THE SAME PROVISIONS AS ANY
OTHER TYPE OF ENTITY. BUT IF THEY ARE CONSIDERED A
PASS-THROUGH, THAT’S A TOTALLY DIFFERENT TOPIC.
AND THAT MAY HAVE TO BE SOMETHING THAT GETS SPOKEN TO
OFF LINE, BECAUSE IT WOULD DEPEND UPON THE FACTS AND
CIRCUMSTANCES. DO YOU AGREE, ELLEN?
>>RIGHT. I KNOW THAT WE TRIED TO MAKE
IT AS CLEAR AS POSSIBLE, THAT THIS PARTICULAR PRESENTATION
OR WEBINAR WAS NOT DESIGNED TO REALLY TALK ABOUT
COALITIONS THAT MAY SERVE AS A PASS-THROUGH OF FEDERAL
FUNDS TO LOCAL PROGRAMS, BECAUSE THE REQUIREMENTS ARE
SLIGHTLY DIFFERENT, OR IT’S JUST — THE CIRCUMSTANCES ARE
DIFFERENT. 44 BUT WE WERE REALLY TRYING TO
FOCUS IN ON OTHER GENERAL NONPROFIT GRANTEES THAT MAY
HAVE OTHER PARTNERS AND SUCH. BUT I AGREE WITH WHAT YOU
WERE SAYING ABOUT, YOU KNOW, IN TERMS OF THE CONCERNS LIKE
IF — IT MIGHT BE A RULE GRANTEE THAT’S CONTRACTING
WITH LAW ENFORCEMENT OR OTHER TYPE OF OVW GRANTEE THAT MAY
BE CONTRACTING WITH — OR MAYBE A SUBRECIPIENT THEIR
LOCAL SCHOOL DISTRICT. SO I THINK THEY WANTED TO SEE
IF THERE ARE DIFFERENT PROVISIONS.
>>OKAY.>>OKAY.
>>TO CONTINUE ON WITH MONITORING REQUIREMENTS, AS A
RESULT OF YOUR MONITORING, YOUR MEETINGS, YOUR REVIEWING
OF THEIR AUDITS AND THEIR FINANCIAL RECORDS, IT MAY BE
THAT YOU HAVE TO DO AN ADJUSTMENT TO YOUR BOOKS AND
RECORDS BECAUSE YOU MAY HAVE PAID FOR SOMETHING THAT YOU
LATER DETERMINED TO BE AN UNALLOWED COST.
AND IF IT TURNS OUT THAT THE SUBRECIPIENT IS TOTALLY NOT
IN COMPLIANCE, YOU MAY HAVE TO INSTITUTE ENFORCEMENT
ACTION, WHICH MAY INCLUDE TERMINATING THE AGREEMENT.
AND THAT’S WHY I EMPHASIZE HAVING REGULAR CONVERSATIONS
WITH THE SUBRECIPIENT SO THAT, AGAIN, YOU ARE NOT
FINDING ALL OF THIS OUT AFTER YOU HAVE BEEN DOING THIS WORK
FOR 12 MONTHS AND ALL OF THE SUDDEN IT TURNS OUT THAT THE
SUBRECIPIENT IS NOT KEEPING GOOD BOOKS AND RECORDS, THAT
THEY ARE PAYING FOR ITEMS THAT ARE CONSIDERED
UNALLOWED, AND, YOU KNOW, YOU 45 HAVE ALREADY PAID OUT LET’S
SAY SEVERAL THOUSAND DOLLARS FOR THINGS THAT ARE NOT
ALLOWED. AND, AGAIN, IT’S ALSO WHY,
WHEN SUBRECIPIENTS TURN IN INVOICES, THERE SHOULD BE
SUPPORTING DOCUMENTATION. AND I WOULDN’T JUST STICK THE
SUPPORTING DOCUMENTATION INTO A FILE SOMEWHERE.
I WOULD ACTUALLY DOUBLECHECK THE NUMBERS AND MAKE SURE
EVERYTHING ADDS UP. BECAUSE, YOU KNOW, FACE IT,
WE ARE ALL HUMAN, WE ALL MAKE MATH ERRORS.
AND SO YOU WANT TO MAKE SURE THAT THE SUPPORTING
DOCUMENTATION AGREES WITH THE NUMBERS THAT ARE ON THE
INVOICES.>>THIS IS CINDY.
I’M GOING TO TRANSLATE ACCOUNTING SPEAK FOR ANYBODY
WHO’S NOT AN ACCOUNTANT. THAT MEANS IF THEY INVOICE
YOU, DO THEY HAVE RECEIPTS AND DO THE NUMBERS MATCH UP.
IT COULD BE AS SIMPLE AS REVIEWING THEIR INVOICES AND
SOMEBODY PUTS DOWN PAID FOR COFFEE FOR A MEETING AND KNOW
YOUR DEPARTMENT OF JUSTICE GRANT DOES NOT ALLOW FOOD OR
BEVERAGE, YOU SAY WE ARE SENDING YOUR INVOICE BACK AND
REVISING IT AND WE’VE REMOVED THE COFFEE BECAUSE THAT’S AN
UNALLOWABLE COST, BUT YOU DON’T WANT THAT TO PILE UP
THAT THEY’VE BEEN PROVIDING COFFEE AT EVERY MEETING AND
THEN YOU NEED TO MAKE AN ADJUSTMENT AND SAY LOOK, WE
CAN’T COVER THIS, WE ARE GOING TO HAVE TO MAKE A
CHANGE HERE, AND YOU ARE GOING TO HAVE TO COVER THAT
OUT OF PRIVATE FUNDS BECAUSE 46 WE CAN’T DO THAT OUT OF
GOVERNMENT GRANTS OR AT LEAST NOT DEPARTMENT OF JUSTICE
GOVERNMENT GRANTS.>>RIGHT, AND AGAIN, I THINK
WE HAVE ALL HEARD HORROR STORIES ABOUT DESK REVIEWS
DONE BY OVW OR DOJ AND OIG AUDITS THAT HAVE BEEN SEVERE
ENOUGH IN THEIR FINDINGS THAT HAVE RESULTED IN
ORGANIZATIONS ALMOST GOING UNDER.
SO THE MONITORING IS DEFINITELY IMPORTANT BECAUSE
WE DON’T WANT TO READ ABOUT ANY OF YOU, YOU KNOW,
UNDERGOING A REALLY PAINFUL OIG AUDIT THAT RESULTS IN YOU
HAVING TO PAY BACK SIGNIFICANT SUMS OF DOLLARS
TO A FEDERAL AGENCY. AND SINCE THE FEDERAL AGENCY
BASICALLY CONSIDERS THE SUBRECIPIENT TO BE YOU, ANY
POTENTIAL LIABILITY THAT COULD BECOME YOUR LIABILITY,
NOT JUST SUBRECIPIENT’S, IF THERE IS SIGNIFICANT
NONCOMPLIANCE. SO AGAIN, I WILL ALWAYS
EMPHASIZE GET AS MUCH TRAINING AS POSSIBLE TO
UNDERSTAND WHAT YOUR GRANT AGREEMENT SAYS, MAKE SURE
THAT YOUR SUBRECIPIENT UNDERSTANDS WHAT THE GRANT
AGREEMENT SAYS, MAKE SURE THEY UNDERSTAND THE FINANCIAL
REQUIREMENTS, THE PROGRAMMATIC REQUIREMENTS,
THE REPORTING REQUIREMENTS. YOU KNOW, DON’T OVERWHELM
THEM WITH INFORMATION, BUT DEFINITELY GIVE THEM THE
TOOLS THAT THEY NEED TO BE SUCCESSFUL SO THAT AT THE END
OF THE GRANT PERIOD ALL THE ORGANIZATIONS COME OUT
LOOKING GOOD AND DON’T END UP 47 WITH QUESTIONED COSTS AND
MONIES OWED BACK TO THE FEDERAL GOVERNMENT.
I KNOW THERE ARE QUESTIONS ABOUT SPECIFIC CHALLENGES OR
WORKING WITH SUBRECIPIENTS. IF YOU HAVE QUESTIONS AFTER
THE WEBINAR I WILL BE GRAD TOO GLAD TO WORK WITH YOU ON
THAT. I WOULD BE GLAD TO WORK WITH
YOU OUTSIDE. THAT’S YOU WANT TO MAKE SURE
THAT WHOEVER YOU ARE PARTNERING WITH IS SPENDING
THE GRANT FUNDS THE WAY THEY WERE INTENDING TO BE SPENT ON
ITEMS ALLOWED AND THERE’S ENOUGH DOCUMENTATION THAT
THEY CAN BACK UP HOW THAT WAS SPENT.
SO IT MAY BE IT LOOKS MORE CREATIVE WITH SAY A SHERIFF’S
DEPARTMENT, WHO YOU MAY NEED TO HAVE A DETAILED INVOICE
DOCUMENTING THEIR HOURS SPENT ON THIS PROJECT IF THEY DON’T
DO A TRADITIONAL TIME SHEET METHOD, BUT YOU STILL HAVE
BACKUP ACTIVITIES DESCRIBED, THE HOURS SPENT, AND YOU KNOW
THEY ARE NOT BUYING COFFEE FOR TRAININGS WITH FEDERAL
FUNDS THAT YOU ARE NOT ALLOWED TO BUY COFFEE WITH.
I WOULDN’T GET TOO TWISTED AROUND SOME OF THE
PARTICULARS AS LONG AS YOU KNOW THAT YOU ARE GETTING —
THAT YOU CAN REALLY STAND BEHIND HOW THAT MONEY IS
BEING SPENT, IF THEY HAVE APPROPRIATE PROTOCOL, IF THEY
ARE TURNING IN RECEIPTS, YOU ARE GETTING COPIES OF THE
RECEIPTS, AND SO GIVEN THAT, YOU ARE IN COMPLIANCE AND
MONITORING IF YOU ARE DOING OVERSIGHT TO ENSURE
COMPLIANCE. 48 IT MAY JUST LOOK SLIGHTLY
DIFFERENT, DEPENDING UPON WHO THE SUBRECIPIENT IS.
>>THIS IS ME. I’M GOING TO TALK ABOUT THE
FEDERAL FUNDING ACCOUNTABILITY AND
TRANSPARENCY ACT, FFATA, AS THE AFFECTIONATE ACRONYM IS,
WHAT IS REQUIRED WITH THAT, AND LET ME GO BACK TO THE
GOAL, THE GOAL WITH THIS IS WHEN WE AS THE NATIONAL
NETWORK TO END DOMESTIC VIOLENCE GET A GRANT FROM THE
OFFICE AGAINST VIOLENCE AGAINST WOMEN DOJ WEBSITE,
THERE’S TRANSPARENCY THAT WE RECEIVED A GRANT TO DO
TECHNICAL ASSISTANCE OR STATE CONFIDENTIALITY, OR CAPACITY
BUILDING, THAT’S PUBLICLY POSTED ON A WEBSITE, THE
GOVERNMENT IS MAKING IT TRANSPARENT.
HOWEVER, IF NNEDV IS SUBAWARDING A LARGE CHUNK OF
A GRANT, SO OVER 25,000, AND NOW I MOVED UP TO 30,000 — I
THINK IT’S MOVED UP TO 30 VERY RECENTLY, OR I THINK
THAT’S ONLY FOR-PROFIT, BUT THE GOAL IS TO MAKE SURE
THOSE LARGE PARTNERSHIPS ARE ALSO BEING VISIBLE.
IT’S NOT ABOUT MAKING SURE EVERY SINGLE CONTRACTED
SPEAKER, FACILITATOR THAT YOU BRING INTO A CONFERENCE IS
POSTED. IT’S REALLY YOUR BIG PARTNERS
ARE VISIBLE ON A WEBSITE. AND SO THE UNIFORM GRANT
GUIDANCE SAYS THAT YOU MUST REPORT ON ANY SUBAWARD OF
OVER25,000 ON THEIR WEBSITE. IF THE INITIAL SUBAWARD IS
LESS THAN 25,000, SO SAY YOU ONLY PLANNED TO SPEND 20,000,
SO YOU ARE NOT REQUIRED TO DO 49 THE FFATA REPORT IMMEDIATELY,
BUT THEN THROUGHOUT THE GRANT, YOU END UP ADDING MORE
TIME, THEN ONCE YOU KNOW THAT YOU ARE GOING TO BE OVER
25,000, SORT OF ONCE YOU’VE OBLIGATED MORE THAN 25,000,
THEN YOU NEED TO FILE A REPORT.
AND YOU MIGHT OBLIGATE IT BY A BUDGET MODIFICATION, OR YOU
MIGHT OBLIGATE IT JUST BECAUSE THE INVOICES ARE
COMING IN AND YOU ARE SEEING THAT WE ARE ALMOST AT 25,000.
SO THE OBLIGATION IS THE POINT.
SO WHEN YOU GET AN AWARD, AND IF YOU’VE NAMED A GRANT
PARTNER FOR SAY $50,000, THE FFATA REPORT IS DUE BY THE
END OF THE MONTH, FOLLOWING THE MONTH WHEN THE SUBAWARD
IS MADE. AND THAT SUBAWARD MEANS WHEN
IT WAS OBLIGATED. AND SO GIVEN THAT, THERE’S A
LITTLE FLEXIBILITY. SOMETIMES YOU DON’T EVEN KNOW
YOU ARE GOING TO GIVE AN ORGANIZATION MORE THAN
$25,000 AT THE BEGINNING OF THE GRANT.
IT HAPPENS LATER ON. MAYBE DO YOU A CHANGE OF
SCOPE OR BUDGET MODIFICATION, YOU ADD AN ACTIVITY.
BUT THE FFATA REPORT IS A REQUIRED ELEMENT FOR ANY
SUBRECIPIENT THAT’S RECEIVING MORE THAN 25,000.
YOU CAN GO TO THE NEXT SLIDE.>>SO THE COMPLIANCE IN
FILLING THIS REPORT OUT, AT THE OBLIGATION POINT, SO
EITHER AT THE INITIAL AWARD, BUDGET MOD OR WHEN YOUR
SUBRECIPIENT HITS THE THRESHOLD, IT’S MANDATORY.
IT’S PROBABLY A SPECIAL 50 CONDITION AND YOUR OVW GRANT
AD WITH AS, AND OBLIGATED AND COMMITTED ARE USED
INTERCHANGEABLY, SO IT — AND WHEN I SAY THAT, IT’S
OBLIGATED BECAUSE IT’S GREAT ON THE WORK, THAT’S THE
OBLIGATION POINT, EVEN IF YOU HAVEN’T GOTTEN THE INVOICE
YET. SO THE OTHER THING TO THINK
ABOUT THAT NNEDV HAS CHOSEN TO DO, BECAUSE WE WERE A
LITTLE NERVOUS THAT AT SOME POINT THE OFFICE OF THE
INSPECTOR GENERAL MIGHT COME IN AND DECIDE THAT ONE OF OUR
VENDORS, THAT WE CONSIDER A VENDOR, THEY MIGHT SAY
ACTUALLY THAT’S NOT A VEND, WE THINK IT’S A SUBRECIPIENT,
WE’VE MADE THE CHOICE INTERNALLY TO DO A FFATA
REPORT FOR ANY ORGANIZATION WHERE WE PROVIDE MORE THAN
25,000, EVEN FOR LIKE SAY ON ACT DEVELOPER, WHO IS CLEARLY
NOT A SUBRECIPIENT, THEY ARE DEFINITELY A CONTRACTOR OR A
VENDOR, AND THAT’S A PERSONAL DECISION THAT WE’VE MADE AS
AN ORGANIZATION, BECAUSE THE FORM TAKES FIVE MINUTES TO
FILL OUT ON THE INTERNET, AND WE JUST WANT TO MAKE SURE
THAT WE ARE NEVER CAUGHT BY OIG HAVING NOT FILLED ONE OF
THESE OUT BECAUSE IT’S SO QUICK TO DO.
BUT THEY ARE REQUIRED FITS A SUBRECIPIENT OVER 25,000.
AND THE SAMPLE REPORT THAT I PROVIDED, I REDACTED ONE OF
OURS, YOU PUT YOUR AWARD NUMBER IN IT, YOUR 2016
XYK014, YOUR AWARD NUMBER IS IN THERE, THE FEDERAL AGENCY
I.D., THE FEDERAL AGENCY NAME, IT MIGHT SAY OFFICE OF
JUSTICE PROGRAMS OR OFFICE ON 51 VIOLENCE AGAINST WOMEN, BUT
THE PRIME AWARDEE DUN’S NUMBER, SO THAT WOULD BE OUR
DUN’S NUMBER, THE ORGANIZATION THAT IS GETTING
THE GRANT, AND THEN OUR NAME, OUR ADDRESS, AND THEN THE
PLACE OF PERFORMANCE. SO WHERE OUR PRINCIPAL
HEADQUARTERS IS. SO WE ARE BASED IN
WASHINGTON, D.C. THE CFDA NUMBER, AND KAREN
HAD MENTIONED THAT, THAT’S THE APPLICATION NUMBER OF THE
GRANT PROGRAM WHERE YOU APPLIED, WHETHER IT WAS AN
LAD GRANT OR T.A. GRANT. THE PROJECT NAME FROM THE
AWARD DOCUMENT. SO IF YOU NAMED YOUR PROJECT
WHATEVER SORT OF QT NAME. WE OFTEN HAVE A NAME FOR A
GRANT APPLICATION. THAT’S WHAT YOU PUT IN THERE.
AND THEN ESSENTIALLY THAT — YOU CAN GO TO THE NEXT SLIDE.
ACTUALLY, GO BACK UP. LET’S STAY ON THAT FOR ONE
MORE MINUTE. THE POINT ON THAT, IT’S
ESSENTIALLY IS THAT THERE’S NOT A LOT MORE THAT YOU ARE
PUTTING IN HERE. THE AMOUNT THAT YOU ARE
PUTTING INTO THIS IS SO SIMPLE THAT THERE’S — IT
GOES ON A LITTLE BIT LONGER. IT’S JUST ONE MORE SCREEN
THAT WE DIDN’T INCLUDE IN HERE.
BUT IT’S SUCH A SMALL AMOUNT THAT YOU DON’T HAVE TO STRESS
OVER DOING ONE OF THESE, AND IN MY OPINION, IT’S BETTER TO
DO THEM THAN IT IS TO RISK NOT HAVING THEM.
SO SOMEBODY ASKED DO WE ARE TO LIST IT ON OUR WEBSITE.
NO. 52 THIS IS NOT SOMETHING ON YOUR
OWN WEBSITE. THIS IS A FEDERAL GOVERNMENT
WEBSITE. IT’S SFRS.GOV WHERE YOU
ACTUALLY GO ON LINE AND FILL THIS OUT FOR ORGANIZATIONS
THAT YOU ARE SUBAWARDING OVER $25,000 TO.
AND SO THIS IS A REQUIREMENT FROM THE UNIFORM GRANT
GUIDANCE THAT IF YOU HAVE A SUBRECIPIENT RECEIVING MORE
THAN $25,000 OUT OF ONE AWARD, SO OUT OF A GRANT, IT
DOESN’T MATTER ANNUALLY OR OVER THE COURSE OF THE GRANT,
IT COULD BE THREE YEAR GRANT AND IT’S 25,000 OVER THREE
YEARS, YOU NEED TO FILL THIS REPORT OUT.
BUT IT’S TRULY FIVE MINUTES. YOU NEED TO GET THE DUN’S
NUMBER OF YOUR SUBAWARD, YOUR SUBRECIPIENT, YOU NEED TO
KNOW THE TOTAL AMOUNT THAT YOU HAVE OBLIGATE TO THEM BY
YOUR GRANT OR YOUR BUDGET MODIFICATION, BUT IT’S SO
SIMPLE TO DO THAT I AM A BIG FAN OF FILLING THEM OUT FOR
ANY SUBRECIPIENT, OR EVEN — PERSONALLY, WE ALSO DO
VENDORS OVER 25,000, AS LONG AS IT’S A COMPANY AND HAS A
DUN’S NUMBER, AND NOT INDIVIDUALS, JUST BECAUSE IT
PROTECTS US. BUT IT’S NOT JUST SOMETHING
YOU STICK ON YOUR WEBSITE. THIS IS A FEDERAL GOVERNMENT
REPORTING WEBSITE. YOU FILL IN THE FORM.
YOU FILL IT OUT, WHAT WE DO IS PRINT IT OUT AND SAVE A
PDF SO WE HAVE PROOF SO WHEN WE ARE AUDITED BY THE
INDEPENDENT AUDITORS AND THEY WANT TO SEE THE FFATA REPORT
FOR THE SUBRECIPIENTS, WE 53 SHOW THEM THIS AND THEY KNOW
WE DID INDEED FILL OUT THE FFATA REPORT.
>>CINDY, THIS IS ELLEN HERE. I’M WONDERING IF YOU
ADDRESSED THE QUESTION I WAS JUST FOLLOWING ABOUT.
BUT ONE OF THE QUESTIONS IS WHAT IS THE DIFFERENCE
BETWEEN OBLIGATED AND COMMITTED FUNDS.
>>IT’S ESSENTIALLY THE SAME. BUT KAREN CAN
ACCOUNTING-SPEAK THAT. BUT IT’S ONCE YOU’VE COMMITTED
THAT MONEY, THAT’S THE POINT WHERE YOU KNOW YOU’RE GOING
TO SPEND IT, SO MAYBE IT’S A BUDGETS MODIFICATION, UP TO
THE AMOUNT YOU ARE GIVING AN AWARDEE, A SUBRECIPIENT, OR
PERHAPS IT’S BECAUSE YOU ARE SEEING AN INVOICE COME IN
THAT’S GOING TO PUSH THEM OVER THE 25 THOUSAND. THAT’S
THE POINT WHERE YOU NEED TO MAKE — YOU’VE GOT ONE MONTH
AFTER THAT TO MAKE THE FFATA REPORT.
>>AND THERE WAS A QUESTION HERE, TOO.
>>I’M SORRY, GO AHEAD, KAREN.
>>IS JUST GOING TO SAY, FOR ACCOUNTING-SPEAK, I LOOK AT
OBLIGATED AS WHEN YOU ARE ABOUT TO ACCRUE THAT AMOUNT.
IN OTHER WORDS, YOU’VE GOT THE INVOICE, AND YOU KNOW
IT’S GOING TO PUSH YOU OVER THE 25,000, THAT’S WHEN I
WOULD GO AHEAD AND DO THE FFATA REPORT.
>>AND THERE WAS ANOTHER QUESTION HERE ABOUT, AGAIN,
WE ONLY HAVE A SNAPSHOT OF ONE OF THE PAGES, BUT THERE
WAS A QUESTION FROM A PARTICIPANT, A SAMPLE REPORT
DOESN’T HAVE ANY INFORMATION 54 ABOUT WHO THE SUBRECIPIENT
IS, WOULDN’T THAT BE THE POINT.
>>IT IS THE POINT. I MEAN, YOU HAVE TO SAY WHO
YOU ARE, THEN WHO YOU ARE GIVING MONEY TO.
BUT WHAT YOU ACTUALLY HAVE TO PUT IN FOR THEM IS SO
MINISCULE, IT’S REALLY THEIR NAMES, DUN’S NUMBER AND
DOLLAR AMOUNT, AND WHERE THEY DO BUSINESS.
SO IT IS QUITE SIMPLE. IT’S NOT TIME CONSUMING.
AND WE CAN MAKE SURE THAT WE SHARE BOTH SCREENS OF THE
SAMPLE WHEN WE SEND OUT FOLLOW-UP MATERIALS, SO YOU
CAN SEE BOTH SCREENS. IT’S A VERY SHORT REPORT.
IF YOU’VE NEVER FILED A FFATA REPORT BEFORE, IT WILL TAKE
THE MYSTERY AWAY.>>THANK YOU.
>>SO KAREN, WE ARE –>>AND THE 25,000, I THINK I
DID MENTION THIS, THE 25,000 OVER THE LIFE OF THE GRANT.
SO IF IT’S A THREE YEAR GRANT AND IT’S 25,000 OVER THE
THREE YEARS, THEN YOU STILL NEED TO FILE THAT FFATA.
IT’S NOT 25,000 IN A GIVEN FISCAL YEAR.
>>AND THEN ANOTHER QUESTION THAT CAME IN WAS DOES THIS
APPLY TO ALL MOU PARTNERS, DOES THIS APPLY TO ALL
GOVERNMENT AGENCIES AND MOU PARTNERS.
>>SO I THINK THE QUESTION IS, IS THAT BASICALLY, THE
FFATA REPORTING IS REQUIRED FOR ANY OF YOUR MOU PARTNERS,
BECAUSE THEY WOULD BE CONSIDERED SUBRECIPIENTS.
>>I’VE SEEN SOME PEOPLE DO MOUS UPON APPLICATION THAT
ARE TECHNICALLY NOT 55 SUBRECIPIENTS THAT ARE MORE
SORT OF SPEAKERS AT A CONFERENCE SO THAT’S MY ONLY,
YOU KNOW — IS IT TRULY A GRANT PARTNER THAT IS DOING A
LARGE CHUNK OF YOUR GRANT OR IS IT AN EXPERT WHO’S GOING
TO COME IN AND DO A SMALL NARROW THING.
BUT IF IT DOESN’T SHOW UP IN THE SCREEN, IT MAY NOT SHOW
UP UNTIL YOU DO THE — I’M NOT SURE IF IT SHOWS UP AT
ALL, BUT YOU CAN GO IN WITH A CLEAN, BLANK FFATA FORM AND
FILL EVERYTHING IN, I’M PRETTY SURE, BECAUSE WE’VE
HAD TO DO THEM WHEN WE DIDN’T NAME THEM IN THE GRANT BUDGET
INITIALLY, BUT OVER TIME, WE HIT A THRESHOLD AND WE WERE
OVER 25,000, AND WE’VE BEEN ABLE TO FILE THEM.
>>AND I THINK TO CLARIFY, THE PARTICIPANT WAS ASKING
DOES THIS ALSO APPLY TO SUBRECIPIENTS WHO MAY BE
GOVERNMENT AGENCIES SUCH AS THE V.A.’S OFFICE OR
SHERIFF’S DEPARTMENT.>>IN MY READ OF THE UNIFORM
GRANT GUIDANCE, THEY ARE PRETTY STRICT ON IF YOU ARE
GETTING MORE THAN $25,000 TO A SUBRECIPIENT IN ONE GRANT,
YOU HAVE TO BE TRANSPARENT ABOUT IT, AND FILE ONE OF
THESE FEDERAL FUNDING ACCOUNTABILITY AND
TRANSPARENCY REPORTS. SO THE ISSUE, IF IT’S AN
INDIVIDUAL, IT’S NOT A REQUIREMENT, SO IF YOU ARE
CONTRACTING WITH A UNIQUE CONSULTANT WHO HAS BEEN ABLE
TO PROVIDE SOME SKILLS, THEY DON’T HAVE A DUN’S NUMBER,
THEY ARE NOT AN ORGANIZATION, IT’S NOT REQUIRED FOR A
PERSON. 56 IT IS REQUIRED IF YOUR
SUBRECIPIENT IS AN ORGANIZATION.
WE HAD TO CHECK THAT OUT BECAUSE WE HAD A CONSULTANT
THAT WE USED HEAVILY DURING A PERIOD WHEN WE DIDN’T HAVE AN
EMPLOYEE AND THEY JUST HIT THAT THRESHOLD.
>>AND IF YOU HAVE SPECIFIC QUESTIONS, FEEL FREE TO REACH
OUT TO ELLEN AND OUR GRANTS AND DEVELOPMENT STAFFER WHO
ACTUALLY FILE THESE REPORTS. I’M HAPPY TO HAVE HER SPEAK
WITH YOU DIRECTLY BECAUSE SHE’S DONE A HANDFUL OF THESE
FOR US, SO IF ANYBODY RUNS INTO PARTICULAR ISSUES REACH
OUT TO ELLEN AND SHE WILL CONNECT YOU TO MY COLLEAGUES
EMILY, AND SHE CAN WALK YOU THROUGH IT.
>>GREAT. AGAIN, WE HAVE A FEW MINUTES
LEFT. WE WILL GO THROUGH THE TWO
REMAINING POLLING QUESTIONS, AND IF THERE ARE ONE OR TWO
MORE QUESTIONS, WE WILL HIT THOSE BEFORE WE CONCLUDE FOR
TODAY. THE POLLING QUESTION, I THINK
IT’S KAREN, DID YOU WANT TO GO THROUGH THIS QUICKLY?
>>RIGHT. POLLING QUESTION NUMBER SIX,
WHEN CONSIDERING WHETHER OR NOT TO CONDUCT ON SITE
MONITORING ON THE SUBRECIPIENT, THE SIZE OF THE
AWARD SHOULD BE A CONSIDERATION.
A, TRUE, B, FALSE. I SEE A LOT OF AS COMING
THROUGH HERE.>>RIGHT.
96 PERCENT OF THE FOLKS RESPONDED A.
THAT’S TRUE. 57>>GOOD.
>>OKAY.>>AND I THINK CINDY HAS THE
NEXT ONE.>>FFATA REPORTING IS NOT
REQUIRED FOR SUBRECIPIENTS RECEIVING $25,000 OR MORE IN
THEIR SUBAWARD, TRUE OR FALSE.
>>AND THAT IS FALSE. IT IS REQUIRED FOR
SUBRECIPIENTS RECEIVING 25,000 OR MORE.
AND THAT’S FOR SUBRECIPIENTS, NOT VENDORS OR CONTRACTORS.
I JUST WANT TO CLEARLY THEY THAT NNEDV HAS MADE A CHOICE
TO DO IT FOR VENDORS JUST BECAUSE WE ARE SCARED OF THE
OIG AND WANT TO MAKE SURE WE NEVER GET CAUGHT ON ANY ISSUE
THAT COULD BE MURKY, BUT IT IS THE REQUIREMENT FOR
SUBRECIPIENTS, AND IF YOU GO BACK TO THE BEGINNING OF THIS
POWER PLANT, A SUBRECIPIENT IS SOMEBODY WHO HAS THE
ABILITY TO MAKE DECISIONS, IS INDEPENDENT, IS HELPING YOU
REALLY IMPLEMENT THE GRANT. THEY ARE NOT UNIQUE VENDORS
DOING CONTRACTED SERVICES.>>JUST TO CLARIFY, WHAT IS
REQUIRED VERSUS WHAT OUR APPROACH HAS BEEN.
>>OKAY. AND SO WE ARE COMING UP ON
THE REMAINING LAST FEW MINUTES OF TODAY’S
PRESENTATION. AGAIN, I KNOW WE HAVE TRIED
TO ADDRESS AS MANY QUESTIONS DURING THE COURSE OF TODAY’S
WEBINAR. SINCE WE ARE COMING TO THE
TAIL END, I’M GOING TO ENCOURAGE, IF YOU HAVE ANY
ADDITIONAL QUESTIONS OR QUESTIONS THAT WE HAVE NOT
RESPONDED TO, TO PLEASE, FEEL 58 FREE TO REACH OUT TO ME, I
WILL SHOW MY CONTACT INFORMATION IN THE NEXT
SLIDE. BUT HERE ARE THE RESOURCES
AND SOME OF THE PIECES THAT VERY CITED THAT WE PROVIDED
THE LINKS TO. AGAIN, YOU WILL GET A COPY OF
THIS POWER POINT IN THE FOLLOWUP E-MAIL YOU WILL GET
FOR TODAY’S WEBINAR WITH ADDITIONAL RESOURCES AND LINK
TO THE EVALUATION.>>SOME OF THE THINGS THAT WE
HAVE HIGHLIGHTED BEFORE, WE HAVE A FACT SHEET ON
SUBRECIPIENT MONITORING. SOME OF YOU MAY HAVE SEEN IT
THAT WE PUBLISHED A YEAR AGO. I WILL BE SENDING THAT TO YOU
BUT HERE’S THE LINK, WE HAVE GIVEN YOU THE WEBSITE TO THE
FFATA WEBSITE WHERE YOU CAN MAKE THE FFATA REPORTS, ALSO
THE UNIFORM GRANT GUIDANCE WHERE WE CITED MOST OF THE
INFORMATION FOR YOU TODAY. HERE’S THE LINK TO THAT,
WHERE YOU CAN LOOK UP THE SPECIFIC DETAILS, AND WE
CITED MOST OF THE SECTIONS WHERE THE DIFFERENT ELEMENTS
THAT WERE COVERED IN TODAY’S PRESENTATION WERE IN.
AND SO WE JUST WANTED TO THANK YOU AGAIN FOR TAKING
THE TIME OUT OF YOUR BUSY SCHEDULES TO PARTICIPATE.
I’LL ALSO WONDERING IF CINDY OR KAREN, IF YOU HAVE ANY
FINAL THINGS THAT YOU WANTED TO SHARE WITH THE GROUP.
>>MY FINAL THING IS REACH OUT TO ELLEN, SHE IS AMAZING.
>>OKAY.>>THANK YOU CINDY.
>>AN SO I WANT TO JUST –>>KAREN AND CINDY — GO
AHEAD, KAREN. 59>>I AGREE, ELLEN, YOU ARE
WONDERFUL. I WOULD ALSO SAY THAT GO
AHEAD AND GET A COPY OF THE UNIFORM GRANT GUIDANCE.
I REALIZE IT IS AN INCREDIBLY BORING READING, BUT AT LEAST
GO THROUGH AND READ THE SECTIONS THAT WE PUT IN THE
SLIDE. THEY WILL BE VERY HELPFUL FOR
ANSWERING SOME OF YOUR QUESTIONS ABOUT WHAT NEEDS TO
BE DONE AND WHAT NEEDS TO BE INCLUDED IN CONTRACTS.
I WILL ADMIT THAT MY COPY OF THE UGG IS HEAVILY
HIGHLIGHTED, AND HAS POST-IT FLAGS EVERYWHERE, BECAUSE I
DO REFER TO IT QUITE OFTEN.>>AND IF YOU ARE LIKE ME AND
DON’T WANT A PAPER COPY, YOU CAN, EVERY TIME YOU NEED TO
LOOK TUP, DO WHAT I DO, WHICH IS ACTUALLY USE GOOGLE AND
SEARCH FOR UNIFORM GRANT GUIDANCE SUBRECIPIENT
MONITORING AND IT ALWAYS POPPING UP AND I CAN REREAD
T. I CAN COPY AND PASTE THE TEXT INTO A WORD DOCUMENT AND
PRINT JUST THAT PIECE, IF YOU DON’T WANT A 500 PAGE VOLUME.
YOU CAN STILL LOOK AT IT ON THE INTERNET.
BUT I COMPLETELY AGREE WITH KAREN, READ WHAT IT SAYS
ABOUT SUBRECIPIENTS SO THAT YOU KNOW YOU ARE COVERED BY
WHAT THE UNIFORM GRANT GUIDANCE REQUIRES YOU TO DO.
>>OKAY. THANK YOU AGAIN EVERYBODY,
FOR TAKING THE TIME OUT OF YOUR BUSY SCHEDULES AND A
PARTICIPATING IN THE WEBINAR. WE WILL MAKE THIS RECORDING
AVAILABLE. GIVE US A COUPLE OF WEEKS TO
GET IT UPLOADED ON OUR 60 WEBSITE.
AGAIN, THANK YOU, AND HAVE A GREAT REST OF YOUR DAY!

Leave a Reply

Your email address will not be published. Required fields are marked *