Virtual Subrecipient Monitoring and Enforcement
The Uniform Grant Guidance (UGG) has now been in effect for five years. One of the major reforms instituted by these federal regulations is in the arena of subrecipient monitoring. Prior to the issuance of the UGG, most pass-throughs satisfied the statutory requirement for monitoring by random or geographic selection criteria, and conducted invasive and exhausting on-site reviews. The UGG changed that with the requirement to base monitoring on risk factors. In addition, the UGG permits technical assistance and training to satisfy the monitoring requirement. Pass-through agency staff have been gravitating towards desk-level and virtual monitoring, and even more so now in light of COVID-19. This training will discuss in detail the legal parameters of the UGG monitoring and enforcement requirements. We will profile the recent guidance from ED’s OCFO on the pass-through review of single audits, and the requirements for management decisions. We will share best practices from states. Whether you work for the pass-through or the subrecipient, you need to understand these expanding requirements.
Who Will Benefit?
This webinar is of value to all federal granting agencies, federal grant recipients, and everyone who works with federal grants, including:
- Grant and program administrators
- Grant program staff
- State, district and school personnel
- Program monitors
What Will You Learn?
- Understand the differences between contracts and subawards.
- Know what data elements must be included in subaward agreements.
- Learn the risk factors pass-through entities must review for subrecipients.
- Determine which type of monitoring subrecipients should receive.
- Know what type of enforcement actions a pass-through entity can take to deal with subrecipient noncompliance.
Brustein & Manasevit, PLLC is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education (CPE) on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: http://www.learningmarket.org.