May 18 – 22, 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 News
Speakers: FEMA Funds for COVID-19 Require Clear Documentation
Local governments seeking to obtain Federal Emergency Management Agency (FEMA) Public Assistance funds to reimburse their response to the COVID-19 pandemic are advised to clearly document how the costs related to emergency actions are necessary and reasonable, and specifically link those costs to their COVID-19 response.
Grants Management News
GAO Urges OMB To Provide DATA Act Guidance
Although the Office of Management and Budget (OMB) released guidance last year designed to ensure federal awarding agencies consistently comply with data standards under the Digital Accountability and Transparency Act (DATA Act) (Pub. L. 113-101), the Government Accountability Office (GAO) explained that OMB still needs to issue more guidance to ensure the integrity of data standards is maintained over time, and to clarify the data governance structure.
Treasury FAQ Addresses Questions on CRF Payments
State and local governments receiving payments under the Department of the Treasury’s Coronavirus Relief Fund (CRF) should be aware that they are not required to spend other federal funding first on emergency public health needs prior to using CRF dollars, Treasury explained in a recent Frequently Asked Questions (FAQ) document.
Single Audit News
ETA Advised To Properly Manage CARES Act UI Funds
As states prepare to experience “extraordinary increases” in the number of Unemployment Insurance (UI) program claims and payments due to disruptions created by the COVID-19 pandemic, the Department of Labor’s (DOL) Employment and Training Administration (ETA) must ensure that states receiving Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (Pub. L. 116-136) supplemental funds (1) establish strong controls for determining beneficiary eligibility to limit potential fraud, and (2) accurately track and report on the funds, the DOL Office of Inspector General (OIG) stressed in a recent advisory report.
NSF OIG Audits JHU; Finds Four Types of Questioned Costs Totaling $91,000
The National Science Foundation (NSF) Office of Inspector General (OIG), in a recent performance audit of incurred costs at the Johns Hopkins University (JHU), questioned four types of costs totaling $91,048. The university agreed with all of the questioned costs.
Grants Intelligence – May 2020
The 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 Expert
What 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.
How 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 ¶501 — Made editorial revisions
¶1410 — Updated the list of AICPA Statements on Auditing Standards
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.
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.
Preparation is Everything: How to Demonstrate Program Impact in Reporting
Scot Scala |Wednesday, June 17, 2020 | 1:00 – 2:30 PM ET
Unless you can demonstrate program impact effectively, grant funders and other supporters may not realize how much you’ve achieved. That’s why it’s critical to focus on measuring impact and reporting performance so it highlights the outcomes and results that matter most to stakeholders. Let a fund development expert show you how, starting with the best way to use the SMART Outcome Measurement Model.