Managing Federal Subawards

1
Managing Federal Subawards

• Robert M. Lloyd
• Consultant on Public Management and Government
  Relations

2
Subgrant vs. Contract Under Grantthe Basic
Policies

• OMB Circular A-110 (Sections ___.5 and
  ___.40-48)
• OMB Circular A-133 (Section ___.210)

3
Important Features to Consider

• Intent
• Nomenclature
• Solicitation and Competition
• Number of Awards
• Use of Applicable Public Policy Requirements in
  the Award
• Timing of Payment

4
Important Features to Consider (Continued)

• Awardee Cost Participation
• Use and Disposition of Property
• Awarding Agency Oversight and Audit
• Termination Provisions

5
Preaward Activities

• Solicitation
• Submission
• Awarding Agency Review
• Award (Federal Fund Identification, Applicable
  Clauses)

6
Post-Award Activities

• ADMINISTRATIVE
• Payment
• Expenditure
• Documentation
• Reporting
• PROGRAMMATIC
• Performance Measures
• Award Results
• The Washington Post Test

7
Subgrant Monitoring

• A Working DefinitionThe continuous collection
  of relevant information about the subgrantee and
  its performance and administration.
• Why Important?One of 14 areas for compliance
  testing in Circular A-133 audits.

8
Monitoring Techniques

• Kick-off so they can catch the ball
• Use Circular A-133 audits
• Use limited scope audits (A-133, ___.230(b)
• Review financial and performance reports
• Document routine contacts

9
Monitoring Techniques (Continued)

• Obtain and Use Third Party Information
• Follow-up on significant developments
• Conduct meaningful site visits
• Provide feedback and technical assistance
• Document, document, document

10
Dealing with Your Auditors

• What is their audit program related to
  subrecipients?
• What if there are findings?

11
Contract Administration

• A Working DefinitionThe act of obtaining what
  you are paying for.
• Risk Variables (Contract Type, Contract Pricing,
  etc.)

12
Contract Administration (Continued)

• FIXED PRICE CONTRACTING
• Delivery
• Inspection
• Enforcement
• Warranties
• Payment
• Waiver of Claims

13
Contract Administration (Continued)

• COST-TYPE CONTRACTS
• Records Retention
• Records Access
• Audit Rights
• Reports
• Enforcement
• Site Visits
• Waiver of Claims