Transcript SubrecipientMonitoringWebcast

Subrecipient Monitoring
Webcast
Presenters
Pat O'Rourke, Irene St. Croix, Bridget Ware
Department of Health and Human Services
Health Resources and Services Administration
Program Integrity Team
Agenda
• Program Integrity
•
•
• Why Monitor
Subrecipients
•
• Funding Subrecipients •
•
• Definitions
• Characteristics of a
Subrecipient
Sub-Award Agreement
Federal Regulations
Pre-Award Monitoring
Post-Award Monitoring
Wrap Up
Program Integrity
• This session is part of HRSA’s Program Integrity series
• Program Integrity aims to help:
o ensure programmatic compliance, efficiency, and
accountability
o identify vulnerabilities that can adversely affect the
integrity of the program
o detect and prevent fraud, waste, and abuse
Why Monitor Subrecipients?
• For program integrity assurance
• To meet Federal regulations reporting
requirements
It’s the law!
Funding Subrecipients
Prime Recipient
Subrecipient
Funding vehicle
can either be a
grant or contract
Definitions
• Prime Recipient – Entity who receives a direct
award from the agency to carry out a Federal
program
• Subrecipient - Non-Federal entity that expends
Federal awards on behalf of the prime recipient
to carry out a Federal program
Definitions
• Subaward - A legal instrument to provide support for
the performance of any portion of the substantive
project or program for which the recipient received
the funds and then awards to an eligible subrecipient.
http://www.hrsa.gov/grants/ffata.html
Who Is Not a Subrecipient?
• A vendor is not a subrecipient
• A dealer, distributor, merchant, or other seller
providing goods or services that is required for
the conduct of the sponsored program
Characteristics of a Subrecipient
Has responsibility for making
programmatic decision
Has its performance measured
against program objectives
Has responsibility for adherence to
applicable programs compliance
requirements
Uses funds to carry out a program
as compared to providing goods or
services for a program
Sub-Award Agreement
• Inform subrecipients of:
– Catalog of Federal Domestic Assistance (CFDA)
number
– Award information
– Notice of Award (NoA) terms and conditions
– Reporting requirements
– Circular A-133 requirement if expending $500K or
more in Federal awards
Sub-Award Agreement
• At a minimum, the sub-award agreement must
include the following:
– Programmatic roles and responsibilities of individuals
at the subrecipient’s organization
– Procedures for directing and monitoring the
programmatic effort
– Procedures to be followed in providing funding to the
subrecipient
– Applicable policy that meets HRSA’s requirement
http://www.hrsa.gov/grants/hhsgrantspolicy.pdf
Federal Regulations
• Cost Principles:
– 2 CFR part 220
– 2 CFR part 225
– 2 CFR part 230
• Federal Funding Accountability and Transparency
Act (FFATA)
• OMB Circular A-133
Federal Cost Principles
Sub-award to State, Local, and Indian
Tribal Governments, 2 CFR part 225 shall
apply
Sub-award to a college or university, 2 CFR
part 220 (Circular A–21) shall apply
Sub-award to a commercial organization,
FAR Subpart 31.2 the cost principles
applicable to commercial organizations
shall apply
Sub-award to some other non-profit
organization, 2 CFR part 230, Cost
Principles for Non-Profit Organizations
(Circular A–122), shall apply
Sub-award to a hospital, 45 CFR 74
(Appendix E) Principles for Determining
Cost Applicable to Research and
Development under Grants and Contracts
with Hospitals, shall apply
The Federal Funding Accountability and
Transparency Act (FFATA)
• The Act was signed on September 26, 2006
• Requires information on Federal awards (Federal
financial assistance and expenditures) to be
made available to the public via a single,
searchable website, which is
http://www.USASpending.gov/
https://www.fsrs.gov/
FFATA Sub-Award Reporting System
(FSRS)
• Reporting tool Federal prime
awardees use to meet FFATA
reporting requirements
– i.e., prime contractors and prime
grants recipients
• FSRS captures and reports sub-award
and executive compensation data
regarding first-tier sub-awards
https://www.fsrs.gov/
FFATA Requirements
• As of October 1, 2010, new Federal grants and contracts
with an initial award that is
$25,000, must
report sub-award and executive compensation data
• If the initial award is below $25,000, but subsequent grant
and contract modifications result in a total award equal to or
over $25,000, the award will be subject to the reporting
requirements, as of the date the award exceeds $25,000
FFATA Requirements when
Funds Reduce
If an initial award equals or
exceeds $25,000
…but is subsequently
de-obligated and falls
below $25,000
The award continues to be subject to the
reporting requirements of the Transparency Act
Reporting Timeline for Prime Recipients
The prime recipient is required to file a FFATA sub-award report
by the end of the month following the month in which the prime
recipient awards any sub-grant or subcontract greater than or
equal to $25,000
https://www.fsrs.gov/
Executive Compensation
• An executive is an officer, managing partner, or
any other employees in management positions
• Total compensation includes cash
and noncash dollar value earned
by the executive during the
subrecipient’s preceding fiscal
year
(17 CFR 229.402(c)(2))
http://www.hrsa.gov/grants/ffata.html
Executive Compensation
80% or more of prior year
annual gross revenues are
from Federal awards; and
$25 million or more in
annual gross revenues are
from Federal awards; and
the public does not have
access to compensation
information filed under SEC
and IRS requirements
80%
$25M
No access
periodic
reports
Names and total
compensation of the
five most highly
compensated
officers are required
Costs Associated with Sub-Awards
• Audit costs and related services
– The costs of audits required by Circular A-133
– Other audit costs included in a cost allocation plan
or indirect cost proposal
• Settlement expenses
– Accounting, legal, clerical, and similar costs
reasonably necessary for:
• The termination and settlement of sub-awards
Pre-Award Monitoring
Pre-Award Monitoring
Post-Award Monitoring
• Review all documentation
• Ensure the correct indirect cost
rate and fringe benefit rate have
been used
• Ensure the budget is reasonable
and only allowable costs have
been included
Post-Award Monitoring
• Review ongoing programmatic
effort and expenditures
• Log communications with the
subrecipient
• Maintain a Risk Assessment Log include entities with A-133 findings
or have been written off for nonpayment
Wrap Up
• Program Integrity is key to meet program
objectives
• Federal regulations require subrecipient
monitoring
• The Prime recipient must report sub-award
data in the FFATA Sub-Award Reporting
System (FSRS)
Resources
• Public Law 109-282 FFATA Legislation
• Public Law 110-252 FFATA Legislation
• Federal Acquisition Regulation
• OMB Guidance on Subaward and Executive
Compensation Reporting
Contact Information
• You may contact the Program Integrity
Team if you have questions
• Email your questions to [email protected]
• Questions specific to grant policy should be
sent to [email protected]