OMB Uniform Guidance: Impact on Subrecipient Monitoring and Management
Jim Carter, Marisa Zuskar, John Sites
The recently released Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards from the Office of Management and Budget (2 C.F.R. § 200) (Uniform Guidance or UG) is intended to ease the administrative burden and cost of compliance for entities that receive Federal awards. The Subrecipient Monitoring and Management section is applicable to all Federal Awards, which will include subawards issued from prime awards made under the Uniform Guidance as of December 26, 2014.
In comparison to A-133, the UG provides additional specific guidance related to subrecipient and contractor determinations (200.330) and requirements for pass-through entities to issue, monitor and manage subawards (200.331).
Overall, grantees should ensure that they address issues associated with subrecipient monitoring because the increased emphasis on internal controls in the Uniform Guidance may increase risk if adequate policies and procedures are not in place or followed.
Huron has summarized the key changes impacting Subrecipient Monitoring and Management and provided recommendations to assist institutions in operationalizing the changes.
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