Course Outline:
Close-outs
This module gets to the point about how a USG project must be finalized. Both Implementing Partners and auditors need to know what the compliance deadlines are, as well as what costs will be allowed or disallowed.
Our experience is that too many recipients end up paying back incurred expenses simply because they did not understand the close-out rules and/or confirm their plans with their Agreement Officers/GMOs/GOs.
Understanding NICRAs and the New 15% Environment
- While the foreign funding state is in flux, it would appear that in certain circumstances, both foreign 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.
Note that HHS/CDC policy is for foreign organizations to receive an Indirect Cost Rate of only up to 8% of MTDC, so understanding full cost recovery under such circumstances will be valuable.
- 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 15% de minimis options (under 2 CFR 200.414 (f)) and whether it even makes sense to apply for a NICRA, if offered.
- 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 costs.
- Exercise to practice preparing a 15% de minimis Modified total direct cost (MTDC).
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 poor internal controls which might lead to fraud and negative audit findings. Many practical examples are discussed to bring internal controls to life.
- 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 pass-through entities.
- 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 entity management 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), entity conflict of interest management (2 CFR 200.112) and management of conflict of interest by employees in procurement (2CFR 200.318 (c)).
- 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 the full 8 hours over both days to receive USG recognized (NASBA) credits.
Day 1:
Day 2:
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
