Uniform Grant Guidance Roundtable Risk Assessments

Transcript:Uniform Grant Guidance Roundtable Risk Assessments:
Uniform Grant Guidance Roundtable Risk Assessments February10, 2016 A risk assessment is the process of identifying potential hazards an organization may face and analyzing methods of response if exposure occurs. What is a Risk Assessment? In regards to compliance, a risk assessment measures two quantities: Magnitude of the potential non-compliance Probability that the non-compliance will occur What is a Risk Assessment? The overall risk assessment determines: Frequency of monitoring Depth of monitoring What is a Risk Assessment? There are two levels to the risk requirements in the Uniform Grant Guidance: Requirements for Federal awarding agencies Requirements for Pass-through entities Uniform Grant Guidance-Risk Requirements Per CFR 200.205, the Federal awarding agency is required to conduct a pre-award review for all awards in order to determine: Eligibility qualifications Financial integrity information Federal Awarding Agency Requirements Additionally, agency pre-award risk evaluation for competitive grants or cooperative agreements must have risk evaluation framework in place that: Identifies if risk review incorporates applicant evaluations, results of eligibility, and/or application quality Risk evaluation criteria must be described in the announcement of funding opportunity Federal Awarding Agency Requirements In evaluating risks for applicants, the Federal awarding agency may consider the following items: Financial stability Quality of management systems and ability to meet management standards History of performance Audit findings Ability to implement requirements Federal Awarding Agency Requirements Pass-through entities can impose requirements on subrecipients in order to: Ensure the federal award is used in accordance with federal statutes, regulations and terms and conditions of the award Ensure pass-through entity can meet its own responsibility to the federal awarding agency Requirements for Pass-Through Entities Per CFR 200.331, pass-through entities must: Evaluate each subrecipient’s risk of non-compliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring Requirements for Pass-Through Entities The following factors should be considered when evaluating subrecipient risk: Subrecipient experience with the same or similar subawards Results of previous audits, including whether the subrecipient receives a single audit and the extent to which the subaward has been audited Whether subrecipient has new personnel or substantially changed systems Extent and results of Federal awarding agency monitoring Requirements for Pass-Through Entities A pass-through entity must assess risk to determine the best monitoring approach. Monitoring must include: Review of financial and performance reports Issuance of management decisions for audit findings on subrecipients Follow up activities ensuring subrecipients take timely,