2011 Financial Guide

Chapters:

Payments
- Using the Grant Payment Request System
- Payment Transaction Timeline
- Understanding the Withholding of Funds
- Drawing Only What is Needed
- Managing Interest Earned
- Understanding the Cash Management Improvement Act
  of 1990
- How to Manage Interest Income
Period of Availability of Funds
- Availability of Awards
- Obligation of Funds
- Expenditure of Funds
- Criteria for Award Extension
Matching or Cost Sharing Requirements
- Match Requirements
- Types of Match
- Source and Type of Funds
- Timing of Matching Contributions
- Records for Match
- Waiver of Match
Program Income
- Introduction
- Accounting Processes for Program Income
- Examples of Program Income
- Procedures for Recovery of Costs Incurred
Adjustments to Awards
- Grant Adjustment Notice
- Incurring of Certain Costs for Which Program Office Approval is Required
- Reprogramming of Funds
Costs Requiring Prior Approval
- Introduction
- Responsibility for Prior Approval
- Procedures for Requesting Prior Approval
- Listing of Costs Requiring Prior Approval
Property and Equipment
- Acquisition of Property and Equipment
- Screening
- Loss, Damage, or Theft of Equipment
- Equipment Acquired With Crime Control Act Block/Formula Funds
- Equipment Acquired With Juvenile Justice Act Formula and Victims of Crime Act Assistance (Formula) Funds
- Equipment and Nonexpendable Personal Property Acquired With Discretionary Funds
- Real Property Acquired With Formula Funds
- Real Property Acquired With Discretionary Funds
- Federal Equipment
- Replacement of Property (Equipment and Nonexpendable Personal Property)
- Retention of Property Records
- Supplies
- Copyrights
- Patents, Patent Rights, and Inventions
Procurement under
Awards of Federal Assistance
- Procurement Standards—
  General Guidance
- Construction Requirements
Allowable Costs
- Introduction
- Compensation for Personal Services
- Conferences and Workshops
- Travel
- Project Site
- Printing
- Publication
- Duplication
- Other Allowable Costs
Food and Beverage
- Introduction
- Allowability of Food and Beverage Costs
- Minimization of Costs of Meals and Refreshments
- Reporting Requirements
Indirect Costs
- Introduction
- Federal Indirect Cost Rate—Negotiated Agreements
- No Approved Plan
- Establishment of Indirect Cost Rates
- Indirect Cost Distribution Bases
- Cost Allocation Plans—Central Support Services
- Lobbying Costs and the Indirect Cost Pool
- Approval of Indirect Cost Rates for Subrecipients
Confidential Funds
- Introduction
- Approval Authorities
- Confidential Funds Certification
- Written Procedures
- Informant Files
- Regional Information Sharing Systems (RISS) Program
- Accounting and Control Procedures
Unallowable Costs
- Introduction
- Unallowable Cost Categories
Subrecipient Monitoring
- Introduction
- Subrecipient Monitoring
- Best Practices
Reporting Requirements
- Introduction
- SF-425 Federal Financial Reports
- Progress/Program Reports
- Reports Required under the American Recovery and Reinvestment Act of 2009
- Government Performance and Results Act
- Reports Required under the Federal Funding Accountability and Transparency Act
Retention and Access Requirements for
Records
- Retention of Records
- Maintenance of Records
- Access to Records
Suspension or
Termination for Convenience
- Provisions of the Grant
- Suspension or Termination of the Grant
- Termination of Grant and Cooperative Agreement Awards by the Award Recipient
Closeout
- First Steps
- Closeout of Discretionary/
  Categorical and Block/Formula Awards
- Refund of Federal Grant Monies and/or Program Income
- Failure to Remit Funds Owed
Audit Requirements
- Audit Threshold
- Audit Objectives
- Audit Reporting Requirements
- Audit Submission Requirements
- Submission of Audit Reports
- Audit Report Confirmation Requests
- Due Dates for Audit Reports
- Audit Compliance
- Resolution of Audit Reports
- Top 10 Audit Findings (Fiscal Year 2009)
- Audit of Subrecipients
- Technical Assistance
- Full-Scope Auditing
- Commercial (For-Profit) Organizations
- Failure to Comply
- Office of Inspector General Regional Offices
The American Recovery and Reinvestment Act
of 2009
- Background
- Recovery Act Programs Administered by the Office of Justice Programs
- Supplanting Rules within the Recovery Act Programs
- Special Conditions
- Reporting Requirements for the Recovery Act
- Government-Wide Data Reporting Requirements
- Technical Requirements
- Delegation of Reporting Requirements under the Recovery Act
- Key Reporting Time Frames
- Data Quality Requirements
Grant Fraud, Waste,
and Abuse
- Introduction
- Detection of Grant Fraud
- Penalties of Grant Fraud
- Fraud Indicators
- Common Grant Fraud Schemes
- Ways to Reduce the Risk of Fraud
Payment Programs
- Introduction
- Bulletproof Vest Partnership
- State Criminal Alien Assistance Program
- Northern Border Prosecution Initiative and Southwest Border Prosecution Initiative

Subrecipient Monitoring

Best Practices

Jump to Section:
Subrecipient Pre-Award and Monitoring Procedures
Subrecipient Legal Agreement/Contract
Award Agreement Penalties & Sanctions

Listed below are best practices that pass-through organizations may consider in developing policies and procedures around subrecipient monitoring.

Subrecipient Pre-Award and Monitoring Procedures

Develop Request for Application with detailed Statement of Work (SOW).
Require the subrecipient to provide a time-phased milestone plan of action based on accomplishments defined in their SOW.
Integrate budget line items into the performance plan.
Require performance/progress reports and supporting documentation with monthly invoices. Performance reports should discuss:
Milestones achieved/to be achieved
Any significant problem, issues, or concerns
Timely accomplishments and delays
Actual cost incurred compared to each budget line item with variances explained.

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Subrecipient Legal Agreement/Contract

Award information: CFDA title, agreement number, amount of award, award name, name of Federal agency
Requirements imposed by law or regulation, special conditions
Approved budget line items
Agreement conditions:
Period of performance;
Level of authorized funding from budget;
Cost, billing, and payment (cost reimbursable);
Records and audits;
Key personnel;
Subcontracting and assignment consent;
Termination and disputes;
Subrecipient invoice format:
Monthly and cumulative columns
Incurred cost should be the same as the budget line items from SF 424a as rows
Line item expenses should have an internal crosswalk to natural accounts
Show total authorized funding
Show backlog: authorized funding less costs to date.
Financial Reporting—Frequency (at a minimum, quarterly, and at the end of the award).

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Award Agreement Penalties & Sanctions

Withholding of disbursements or further awards
Disallowance of cost
Suspension/termination of award
Suspension/Debarment
Civil lawsuit, or
Criminal prosecution.

Financial Management Tip

To proactively monitor subrecipients:

Read award/contract documents carefully.
Ask for explanation and clarity; don???t assume.
Request a deviation or exception if needed as issues arise.
Document transactions, agency guidance, performance evaluations, etc., in writing.
Keep documentation at hand.
Document, document, document! If it isn???t documented, it doesn’t exist!

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Office of Justice Programs
810 Seventh Street, NW · Washington, DC 20531

Bureaus and Offices