Transcript UNIFORM GUIDANCE AT K-STATE SUBAWARDS & SUBRECIPIENT MONITORING 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

UNIFORM GUIDANCE AT
K-STATE
SUBAWARDS
& SUBRECIPIENT
MONITORING
2 CFR Part 200 – Uniform Administrative
Requirements, Cost Principles, and Audit
Requirements for Federal Awards
200.332 Fixed Price Subawards
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Prior written approval from Federal awarding agency
Limited to the federal Simplified Acquisition Threshold, currently $150,000.
Per COFAR FAQs: It is allowable to have multiple subs to same subrecipient
that total more than $150K if they have distinct statement of work. All subs
have to have prior written approval.
Section 200.201(b)(1) states that fixed amount awards and subawards “if the
project scope is specific and if adequate cost, historical, or unit pricing data
is available to establish a fixed amount award based on a reasonable estimate
of actual cost. . . . Accountability is based on performance and results.”
Section 200.201(b)(2) states that a fixed price award cannot require
mandatory cost share or matching.
Section 200.201(c)(2) states that the subrecipient must certify in writing to
pass-through entity at the end that project was completed. If the required
level of activity was not carried out, the amount of the subaward must be
adjusted.
200.330 Subrecipient & contractor determinations
 Basically the same guidelines as before . . .
 Subrecipients:
• Performance measured against objectives of Federal program
• Programmatic decision making
• Adherence to Federal program requirements
 Contractors:
• Provides goods/services within normal business operations
• Provides similar goods and services to many different purchasers
• Operates in a competitive environment
• Not subject to compliance requirements of the Federal program as a
result of the agreement.
200.311 Pass-through Entities - IDC
• All pass-through entities must . . .
• (a)(4) Indirect cost rate
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If the subrecipient has a federally recognized, negotiated rate,
use it.
If not:
• Negotiate a rate with the subrecipient or
• Use the de minimus rate of 10% MTDC
200.331 Pass-through Entity - Risk
200.331 (b) Evaluate each subrecipient's risk of
noncompliance with Federal statutes, regulations, and the
terms and conditions of the subaward . . .
PreAwards
 Check suspension and debarment
 Check restricted parties list database
 Subrecipient Commitment Form on PreAwards website
SPA
 Is subrecipient subject to Single Audit (Subpart F—Audit Requirements
formerly A-133 Audit)?
 If not, we will monitor invoices and expenditures more closely.
200.331 Pass-through Entity - Monitoring
(d)(1) Reviewing financial and performance reports required
by the pass-through entity.
SPA & business offices review financial reports. PIs receive
and review performance reports: You should have the PI
approve invoices before payments are issued to
subrecipients so that PI can alert us if we need to hold
payments for lack of performance. PI certification forms
required before final payment will be approved by SPA.