May 11 – 15, 2020
The following post is from Thompson Grants weekly delivery of grant- and audit-related news and analysis from their editors, conveniently organized in pre-award, post-award and audit categories. It also provides readers with the latest Grants Intelligence articles from experts in the grants community, responses to subscriber questions, links to their most recent newsletter issues and e-learning offerings, and upcoming webinars.
Because the nation’s response to concerns about the Novel Coronavirus 2019 (COVID-19) has dramatically affected traditonal grant processes, Thompson Grants is now offering a continuously updated roundup in our Top News section containing grant-specific links for grant applicants and recipients posted by federal agencies, as well as from Congress and the Office of Management and Budget. The roundup is available here.
Grants Development NewsCOVID-19 Could Delay Emergency Preparedness Reports
The 2020 National Preparedness Report by the Department of Homeland Security (DHS) Federal Emergency Management Agency (FEMA) is expected to highlight state and local emergency preparedness gaps to enable the agency, along with the Office of Management and Budget (OMB) and Congress, to better prioritize future grant funding for disaster preparation. However, disruptions created by the response to the COVID-19 pandemic could delay the anticipated Oct. 30 release date, according to a recent Government Accountability Office (GAO) report. These delays also could affect the 2021 National Preparedness Report, which is slated for release on Oct. 29, 2021, and is expected to contain new information related to federal emergency preparedness weaknesses.
Grants Management NewsHHS Urged To Curtail Medicaid Improper Payments
Noting that the level of improper payments in the Medicare and Medicaid programs continued to hover around $103 billion for federal fiscal year (FY) 2019, the Government Accountability Office (GAO), in a recent report to the Department of Health and Human Services (HHS), stressed the “critical importance” for the agency to address high-priority open recommendations under the Medicaid program. GAO also sought responses to unaddressed concerns from previous reports related to grant programs managed by the departments of Homeland Security (DHS), Housing and Urban Development (HUD), and Transportation (DOT).
READ MOREOHRP, FDA Release COVID-19 Guidance for Trials
The Department of Health and Human Services (HHS) Office for Human Research Protections (OHRP) has released guidance on meeting Common Rule requirements when COVID-19 affects clinical trials, which promises that the agency “will take into account the specific circumstances that institutions and investigators are experiencing, and will use available flexibility in its decision making as institutions and investigators implement actions necessary to protect public health, while still appropriately protecting research subjects.”
Single Audit NewsGAO Provides Exceptions to GAGAS CPE Requirements Due to COVID-19
The Government Accountability Office (GAO), in response to concerns related to disruptions created by the COVID-19 pandemic, recently issued an alert to its 2018 version of the Government Auditing Standards (GAGAS) that provides auditors more time to complete their continuing professional education (CPE) requirements.
READ MOREAICPA Seeks Answers To COVID-19 Audit Questions
The American Institute of Certified Public Accountants’ (AICPA) Government Audit Quality Center recently sent a letter to Office of Management and Budget (OMB) officials requesting answers to questions raised by auditors about how the COVID-19 pandemic disruptions, along with provisions in subsequent congressional supplemental packages, might affect upcoming single audits and the 2020 Compliance Supplement.
Grants Intelligence – May 2020The Bayh-Dole Act: 40 Years and Counting!
In December 1980, Congress passed the Bayh-Dole Act (Pub. L. 96-517), implementing special rules for patent rights of inventions resulting from federally funded research. With 2020 marking the 40th anniversary of its passage into law, the Bayh-Dole Act, and more specifically how its provisions relate to the federal government’s “march-in” rights, has been appearing in the news more frequently as lawmakers have been discussing possible steps to, among other things, lower drug prices. This discussion became more topical as the novel coronavirus spread across the world, pressuring countries to quickly create a vaccine that is both safe and affordable. On March 6, President Trump signed the Coronavirus Preparedness and Response Supplemental Appropriations Act (Pub. L. 116-123), which provided the Department of Health and Human Services (HHS) with $3.1 billion to develop a vaccine. As companies and scientists partner with federal agencies to work to create a vaccine, it’s important for nonfederal entities (NFEs) to be reminded of the Bayh-Dole Act and its tremendous benefits to NFEs.
Ask the ExpertWhat Does It Mean for a Grantee To Identify Awards ‘In Its Accounts?’
Q: I have a question regarding §200.302 of the uniform guidance, particularly this portion: “(1) Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Federal program and Federal award identification must include, as applicable, the CFDA title and number, Federal award identification number and year, name of the Federal agency, and name of the pass-through entity, if any.” What does “in its accounts” refer to? For instance, as a nonprofit organization/sub-recipient, I maintain all of our grant files which contain award documentation with the CFDA title/numbers, federal award numbers, etc. But these exact details are not listed in our accounting system (QuickBooks). Where exactly is this information required to be recorded, and how many times over does it need to be identified? Thanks so much for your help. Christy in Las Vegas, Nev.
READ MOREHow Do We Handle Waived Indirect Costs?
Q: How do you account for or record cost share contributions in the form of “waived indirect costs”? Thanks!
Monthly Newsletters and Recent Handbook Updates
We take all the news each month and compile into a monthly newsletter for your files, and make continuous updates to our publications to keep them current.
Federal Grants Development Handbook:
¶270 — Updated links and made editorial revisions
¶113 — Updated section to include information about the GREAT Act
¶114 — Created new section to discuss COVID-19 response’s implications for grants
Federal Grants Management Handbook:
Federal Grants Management Handbook Newsletter, May 2020
¶370 – Added new section entitled “COVID-19 Implications for Grants”
¶477 – Added information about the GREAT Act, Performance.gov and made other editorial revisions
¶478 – Added information about the GREAT Act and made other editorial revisions
Single Audit Information Service:
Single Audit Information Service Newsletter, May 2020
Guidance ¶332 — Made editorial revisions
Guide to Managing Federal Grants for Colleges and Universities:
Federal Grants News Newsletter, May 2020
¶370 — Updated information on guidance for federal contractors
¶477 – Added information about the GREAT Act, Performance.gov and made other editorial revisions
¶478 – Added information about the GREAT Act and made other editorial revisions
| WEBINARS AND TRAINING OPPORTUNITIES YOU DON’T WANT TO MISS |
Indirect Costs and Cost Allocation Plans – An eLearning Course
Karen Norris | Self-guided course
In this eLearning course, Karen Norris, a national consultant and subject matter expert for k4rnoco, a K4ren Norris Company, and formerly with Thompson Information Services, will discuss the changes in the new uniform grant reform guidance related to calculating and charging indirect costs to federal grants. The presentations will include: an overview on indirect cost rates, including developing and submitting indirect cost rate proposals; how the rules governing indirect costs have changed; and provide practical examples how agencies can prepare for these changes.
May’s COVID-19 Grants Management Update
Jack Reagan |Thursday, May 21, 2020 | 1:00 – 2:30 PM ET
During these unprecedent times, the grants management process has been changing. With each month bringing new regulations, researching federal aid for your organization can be time consuming. From the new $2 trillion Coronavirus Aid, Relief and Economic Security (CARES) Act to The Office of Management and Budget’s (OMB) actions affecting grants management, it’s critical to understand the opportunities and how to take advantage of them. This new webinar provides the up-to-date information you need to take the right steps.
Be Prepared for Post-Pandemic Audits
Dismas Locaria |Thursday, May 28, 2020 | 1:00 – 2:30 PM ET
What happens when noncompliance is discovered after federal funding has been awarded? You immediately face disclosure obligations. It is critical to handle disclosure and agency interaction effectively. It helps if you can point to a strong compliance program that shows your commitment to meeting your obligations under the uniform guidance. Preparing now can make all the difference in avoiding severe enforcement, including staggering penalties under the False Claim Act. Let an expert on the uniform guidance show you how.
Top 10 Mistakes in Organizational Policies and Procedures that Put You at Risk for Noncompliance
Elizabeth Gombash |Tuesday, June 02, 2020 | 1:00 – 2:30 PM ET
Even if you’re an expert on federal grant rules and regulations, you may be at risk for common mistakes that lead to serious audit findings. That’s because knowing the regulations is just the start. You must also understand how those regulations affect organizational policies throughout the grant lifecycle. And you must make sure your entire staff translates those policies into compliant grant and financial procedures every day. Start by learning where these 10 top mistakes arise—and the best strategies for avoiding them.
Asking Permission vs. Begging Forgiveness: Unraveling the Need for Prior Approval
Toni Demaglio |Tuesday, June 09, 2020 | 1:00 – 2:30 PM ET
There are times when it may be better to beg forgiveness than to ask permission. Modifying your grant budget isn’t one of them. Neither is making changes in your project activities. Procuring goods or services without prior written approval from a federal funding agency can trigger consequences no grant recipient wants to face: unallowable costs. In this upcoming webinar, a seasoned grants expert shows you steps you can take to seek the required permission—and win approval.