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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 - PowerPoint PPT Presentation
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Subrecipient MonitoringWebcast
PresentersPat 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:oensure programmatic compliance, efficiency,
and accountability o identify vulnerabilities that can adversely
affect the integrity of the program odetect 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
Funding vehicle can either be a grant or contract
Prime Recipient
Subrecipient
Government Agency(HRSA)
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 responsibility for adherence to applicable programs compliance requirements
Has its performance measured against program objectives
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 equal to or over $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
$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/
June 2014
SUN MON
TUE WED THURS FRI SAT
1 2 3 4 5 6 7
Subaward
Agreement
Signed
8 9 10 11 12 13 14
15 16 17 18 19 20 21
22 23 24 25 26 27 28
29 30
July 2014
SUN MON TUES WED THURS
FRI SAT
1 2 3 4 5
6 7 8 9 10 11 12
13 14 15 16 17 18 19
20 21 22 23 24 25 26
27 28 29 30 31
FFATA
Subaward
Report Due
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
Verify the subrecipients have not been debarred or suspended from receiving Federal funds at https://www.sam.gov/portal/public/SAM//
Determine whether the applicant is a subrecipient or a vendor
Pre-Award Monitoring
Request agreement documents to
be returned at a reasonable
deadline
Verify subrecipient written
agreement has been completed
with all required information
Review the budget to ensure the
correct rates are being used
Review
Document
Repeat
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
Review
Document
Repeat
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 non-payment
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
• 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]
Contact Information