Dear Colleagues,
This
is the fourth in a series of messages concerning the Uniform Guidance, and what
it means to CNCS grantees. The regulation section number denotes where in the
Uniform Guidance the rule being discussed in this bulletin is found.
§200.331 Requirements for Pass-Through Entities - Delineates the responsibilities of those recipients
that have subrecipients of federal funds.
* All of the requirements placed on the prime
grantee must flow through to the subrecipients, and
* While grant requirements specific to the type of organization have been
consolidated, some specific requirements,
notably indirect costs, continue to apply based on the type of organization. As such, recipients
and subrecipients must follow the indirect cost requirements which are applicable to their
type of organization, i.e., subrecipients do not follow the requirements of the
type of organization which is granting them funds.
Why is this important?
CNCS will be focused on ensuring that prime
grantees are acting in accordance with their duties under 2 CFR § 200.331 if
they are subawarding funds, and that they have comprehensive policies and
procedures in place which ensure that all terms and conditions are met
by their subrecipients. CNCS is also focused on ensuring that
pass-through entities have effective monitoring tools that they are utilizing
to confirm subrecipients are in compliance with all Uniform Guidance
requirements.
What You Should Do:
All grantees that subaward should obtain training
to ensure that they are well positioned to carry out all of the duties and
requirements placed on them under 2 CFR §200.331. Grantees
that are pass-through entities must be prepared to evaluate subrecipients’ compliance
with their subawards, monitor the activities of their subrecipients, impose
specific conditions under 2 CFR § 200.207 as necessary, ensure required audits
are completed, and take enforcement actions under 2 CFR § 200.338 when and if
necessary.
Grantees should ensure that they have taken the
necessary steps to be in compliance with the Uniform Guidance. Adherence to the
Uniform Guidance is important to meet grant requirements and to be found fully
compliant in any future audits or monitoring reviews.
Do not send documentation to CNCS to demonstrate
compliance. When conducting future grant oversight, CNCS staff will
request specific documents and records when necessary.
If you have concerns or questions regarding requirements
for pass-through entities, please send them
to blewis@cns.gov. Your feedback and
questions will help guide us in developing additional information and assistance.
In Service,
Dana Bourne, Chief Grants Officer Corporation for National and Community Service Grant Offices Washington, DC and Philadelphia, Pennsylvania
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