FEDERAL GRANTS COMPLIANCE

FEDERAL GRANTS COMPLIANCE EXPERTISE

Capital Edge combines our team’s experience in consulting, public accounting, industry, and government to provide you with unmatched Federal Grants Compliance expertise. Our consultants provide government contractors and nonprofit organizations with a wide variety of services focused on overcoming their most difficult compliance challenges. We are committed to helping organizations overcome these challenges so that they can focus on what is most important, which is the successful implementation of their Federal award.

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Federal Grants Compliance Updates​

Watch our Federal Grants Compliance Expert Dan Durst as he covers the top issues currently on the minds of Federal Grant recipients. Commentary on OMB’s Proposed Updates to Uniform Guidance – 2 CFR 200 Finalization in the Federal Register are here!

WATCH BELOW:

Over 200 Public Comments were Received  on the Guidance for Grants and Agreements Proposed Rule by the Management and Budget Office on 01/22/2020.

Our team received an advanced copy of the final updates.  We are in the process of performing a complete analysis of the changes, and will be sharing an update soon.

Capital Edge’s “Federal Grants Compliance Updates” are your best source for the latest developments impacting the administrative requirements, cost principles, and audit requirements relevant to your Federal grants and cooperative agreements.

Tune in for expert analysis and commentary from our team which actively works with some of the largest Federal award recipients in the nation. See calendar below and sign up for our NEWSLETTER!

Federal Grant Lifecycle

We can provide value to your organization throughout the grant lifecycle in many different ways, tailored to the needs of your organization.

Pre-Award Phase

The pre-award phase represents the beginning of the grant lifecycle, which includes important considerations regarding the pricing of the award and maximizing cost recovery efficiency over the full award term. This phase is also the organization’s opportunity to ensure that it is capable of complying with the compliance requirements associated with the new award.

Award Phase

The award phase is the shortest in the grant lifecycle but perhaps one of the most important for recipients. Recipients should pay close attention to negotiations occurring during this phase as the agreements reached will impact the entire award term.

Post-Award Phase

The post award phase is where the rubber meets the road. Recipients must deliver on all of the promises made during the award phase. Capital Edge thrives in the post award phase and can provide tremendous value to organizations that are struggling to manage the Federal award in compliance with Federal statutes, regulations, and specific terms and conditions. Recipients can expect to be audited each year for compliance with Uniform Guidance (2 CFR 200) and awarding agency supplements. 

Indirect Cost Recovery for Grantees

Uniform Guidance introduced sweeping changes to administrative requirements, cost principles, and audit requirements for Federal awards to non-Federal entities. These changes brought new responsibilities and opportunities to non-Federal entities. Unfortunately, most publicly available guidance focuses primarily on helping non-Federal entities cope with the added responsibilities, leaving little consideration to the new opportunities that are now available. The most overlooked of these opportunities is the ability, but more importantly the right, to Indirect Cost Recovery.

If your organization has never had a Federally negotiated indirect cost rate or if you have elected to use the “de minimis” rate, please provide us the opportunity to show you how much money you could be recovering for your organization. Capital Edge Consulting is actively working with Federal grantees all over the country to develop and negotiate Federal indirect cost rate agreements. Our industry experts will guide you through the calculation, proposal, and negotiation of indirect cost rates.

To the right-hand side, you will find some upcoming training courses and thought leadership. If you’d like to learn more about our approach, experiences, and solutions, we hope to see you at one of the following training sessions or contact us directly.

Prior to Uniform Guidance, the ability to apply for and be awarded a negotiated indirect cost rate agreement (NICRA) was heavily dependent on the Federal awarding agency. Since December of 2014, non-Federal entities have to option to submit an indirect cost rate proposal and negotiate a rate based on the prior years cost information. Organizations owe it to their mission and to their stakeholders to take full advantage of and recover every dollar of funding that is available. As budgets become tighter and meetings become more difficult due to reductions in funding, organizations may find relief by recovering more indirect costs on their Federal grants.

Latest Questions Being Asked About Federal Grants Compliance

August 2020

On January 22nd, 2020 OMB issued “proposed guidance” in the Federal Register to address revisions to Uniform Guidance (2 CFR 200) in accordance with the 5 year revision requirement. The proposed revisions were subject to a public comment period. On March 23rd, 2020 the comment period closed with over 200 public comments submitted. An OMB official indicated at a recent conference that the final guidance could be issued in the Federal Register as early as this August.

OMB’s proposed updates document is 257 pages in total and provides for revisions that impact all 6 subparts of Uniform Guidance. Two of the most high profile post award related updates are as follows:

1. 2 CFR 200.321 Domestic preferences for procurements.

(a) As appropriate and to the extent consistent with law, the non-Federal entity should, to the greatest extent practicable under a Federal award, provide a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States (including but not limited to iron, aluminum, steel, cement, and other manufactured products). This term must be included in all subawards including all contracts and purchase orders for work or products under this award.

2. 2 CFR 200.414 Indirect (F&A) costs.

(h) All rate agreements from non-Federal entities must be available publicly on an OMB Designated Federal website.

On March 19th, 2020 OMB Issued Memorandum M-20-17 which provides short term relief regarding the administrative, financial management, and audit requirements under 2 CFR 200 for recipients affected by the loss of operational capacity and increased costs due to the COVID-19 crisis. This memorandum provided relief in the following areas:

  • Flexibility with SAM registration.
  • Flexibility with application deadlines.
  • Waiver for Notice of Funding Opportunities (NOFOs) Publication.
  • No-cost extensions on expiring awards.
  • Abbreviated non-competitive continuation requests.
  • Allowability of salaries and other project activities.
  • Allowability of Costs not Normally Chargeable to Awards.
  • Prior approval requirement waivers.
  • Exemption of certain procurement requirements.
  • Extension of financial, performance, and other reporting.
  • Extension of currently approved indirect cost rates.
  • Extension of closeout.
  • Extension of Single Audit submission.

On June 18th, 2020 OMB Issued Memorandum M-20-26 which rescinded M-20-17 and provided an extension for the following two flexibilities through September 30, 2020:

  1. Allowability of salaries and other project activities.
  2. Extension of Single Audit submission.

Auditors are likely to have an increased focus on the adequacy of organizational policies and procedures due to the inclusion of an enhanced Internal Controls part in the August 2019 Compliance Supplement by OMB. The Compliance Supplement is a document that identifies existing important compliance requirements that the Federal Government expects to be considered as part of an audit required by the Single Audit Act Amendments of 1996 and 2 CFR part 200, subpart F. Part 6 titled “Internal Controls” in the 2019 Compliance Supplement contains illustrative control activities that an auditor can expect to find in an adequate set of policies and procedures. This new set of information that is being furnished to auditors will act as a benchmark against which auditee organizations may be measured.

Very few answers are available at this time due to the rapidly evolving situation. Early positions have been expressed by the Federal Acquisition community that the PPP Loan should be considered a credit (2 CFR 200.406) toward existing Federal funding when used to fund the same labor expense. There has not been any authoritative guidance provided thus far that specifically addresses this issue. If your organization received the PPP Loan or other CARES Act Relief Funds we advise that you check back with our information resources often so that you can make decisions based on the most accurate information available.

On June 18th, 2020 OMB Issued Memorandum M-20-26 which rescinded M-20-17 and provided an extension for two of the flexibilities through September 30, 2020. When addressing the allowability of salaries and other project activities the memorandum said the following regarding the PPP loan and other CARES Act funding:

“Under this flexibility, payroll costs paid with the Paycheck Protection Program (PPP) loans or any other Federal CARES Act programs must not be also charged to current Federal awards as it would  result in the Federal government paying for the same expenditures twice.”

 

Yes, Fund payments are considered to be federal financial assistance subject to the Single Audit Act (31 U.S.C. §§ 7501-7507) and the related provisions of the Uniform Guidance, 2 C.F.R. § 200.303 regarding internal controls, §§ 200.330 through 200.332 regarding subrecipient monitoring and management, and subpart F regarding audit requirements. The CFDA number assigned to the Fund is 21.019.

Meet The Experts

Have Questions or need Consulting Expertise Regarding Federal Grants Compliance

We Can Help!

Contact the experts at Capital Edge Consulting today.
Call: (855) 227-3343 or Email: federalgrants@capitaledgeconsulting.com

Federal Grants Compliance Resources

Upcoming Events For Federal Grants Compliance

PUBLIC GRANTS COMPLIANCE TRAINING

Samples of On Demand and upcoming training options are above.  To see the full Calendar of training and events for federal grants compliance, view the full calendar.

Contact us if we can assist with scheduling training personalized for you or your organization.

Downloadable Datasheets

Grants Capability Brief
Indirect Cost Recovery
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