Understanding NICRA and the New 10% Environment
- While USAID is still interpreting exactly how to implement some of these rule changes for non-US
organizations, it would appear that in certain circumstances, both Prime and Subrecipients may be able to
obtain a NICRA or Negotiated Indirect Cost Rate Agreement (or “Overhead Rate”) which is a fairly
complicated exercise. Understanding, at a high level, the processes for calculating your (Prime) rate or
reviewing your sub-recipient’s submission to you as the Prime Recipient. Consideration of the new 10%
de minimis options (under 2 CFR 200.414 (f)) and exercise of how to transition to the 10% environment.
- How to prepare or review an organization’s Cost Policy Statement, which is a written policy that outlines
the costs considered as direct, the costs considered to be indirect, and the rationale to support those
- Exercise to practice preparing a 10% de minimis Modified total direct cost (MTDC).
- How this can affect the final audit, relating to Management, Programmatic, Human Resources, Financial,
Legal, Logistics and Public Relations
Internal Controls/Green Book Summary
- Overview of the new 2 CFR 200.303 section on Internal Controls or the “Green Book” and guidance on
how to competently implement the Green Book within the organization to safeguard it from negative
Sub-recipient management; sub agreement preparation (very light) and sub auditing
- An organisation may concurrently receive donor funding as a recipient, a sub-recipient, and a
contractor, depending on the substance of its agreements with Federal -Awarding Agencies and
- A sub-award is for the purpose of carrying out a portion of a Federal award and
creates a Federal assistance relationship with the sub-recipient.
- Requirements of 2 CFR 200.332:
Requirements for pass-through entities, including the required information for a sub-award agreement,
how to perform and evaluate the pass-through entity’s risk assessment procedures prior to the
sub-award and what is required in terms of adequate sub-recipient monitoring.
- Address the differences between a sub-award and a Fixed Amount Awards and provide guidance on what type of award should
be used in different circumstances.
Conflict of Interest/Fraud/Ethics
- Fraud, conflicts of interest and unethical practices may all ultimately lead to an organization’s
reputational damage if not properly managed.
- Management and Auditors have varying levels of responsibility in managing and reporting related to fraud, ethics and conflicts of interest. Ethics and
conflict of interest violations can result in fraud being committed.
- Assisting of non-federal entitymanagement in understanding their obligations in the prevention and detection of fraud, conflict of
interest and ethics violations, including requirements for fraud reporting (2 CFR 200.113 & 45 CFR
75.113), entity conflict of interest management (2 CFR 200.112 & 45 CFR 75.112) and management of
conflict of interest by employees in procurement (2CFR 200.318 c1 & 45 CFR 75.327c1). Assessing
the impact of conflict of interest and ethics violations, and the resulting risk of fraud being committed.
- Reporting of fraud, as required by the Government Auditing Standards and the OIG Guidelines for
financial audits contracted by foreign recipients.
Participants are welcome to ask questions to clear-up any issues or concerns during the Q&A sessions which are held throughout the course
Participants are required to attend both days to receive credits.
SustainAbility Solutions PC is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org