Risk and Subaward Management under the Uniform

Transcript:Risk and Subaward Management under the Uniform:
Risk and Subaward Management under the Uniform Guidance U.S. Department of Education Purpose and Use of this Presentation The Department of Education is providing this presentation to help its grantees understand the contents of the Uniform Guidance and should be viewed after or alongside of the regulations. It is not a substitute for reading the regulations. To get the most out of this presentation, view this as a notes page. The notes section of each slide provides information to supplement the points on the slide. To change to notes page: Go to View and click on Notes Page. Learning Outcomes Understand concepts of risk and risk-based monitoring; Understand the risk requirements in 2 CFR Part 200; Be able to find the relevant regulations in 2 CFR Part 200; and Apply this knowledge in your job. Uniform Guidance Title 2 of the Code of Federal Regulations, Part 200 (2 CFR Part 200) Accepted by the Department of Education in 2 CFR Part 3474 “This guidance does not change or modify any existing statute or guidance otherwise based on any existing statute.” Authorities to consider when using 2 CFR Part 200 When does 2 CFR Part 200 start? Uniform Guidance (2 CFR Part 200) applies to: New and Continuation grants awarded on or after December 26, 2014 Former regulations (EDGAR Part 74 or 80 and OMB circulars) apply to: Grants awarded prior to December 26, 2014 Relationships and Key Terms Subaward or Contract? The relationship, rather than the document title, is the basis for determining which requirements are applicable. Know the Difference. Definitions: Pass-through entities A non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program (§200.74). At ED: State-Administered Formula Grants: SEAs, other grantees which make subawards Discretionary Grants: under EDGAR 75.708 or authorizing statute, some discretionary grantees may make subawards. These are not the same as partnerships. Definitions: Subrecipient and Contractor A pass-through entity must determine the relationship and the applicable requirements: Subrecipient means a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program (§200.93). Contractor means an entity that receives a contract as defined in 200.22 Contract (§200.23). §200.330 explains the roles of subrecipients and contractors Understanding Risk What is Risk? (GAO – The Green Book) Risk is the possibility that an event will occur and adversely affect the achievement of objectives. What