• I. General
  Information
• II. Preaward
  Requirements
• III. Postaward
  Requirements
• IV. Organization
  Structure
• 
  V. Appendices

Chapters:

• 3.1 Payments
  • Using the Grant Payment Request System
  • Payment Transaction Timeline
  • Understanding the Withholding of Funds
  • Draw Only What is Needed
  • Managing Interest Earned
  • Understanding the Cash Management Improvement Act
    of 1990
  • How to Manage Interest Income
• 3.2 Availability of Funds
  • Availability of Funds
  • Obligation of Funds
  • Expenditure of Funds
  • Criteria for Award Extension
  • Project Extension Guidance
• 3.3 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
• 3.4 Program Income
  • Introduction
  • Accounting Processes for Program Income
  • Examples of Program Income
  • Procedures for Recovery of Costs Incurred
• 3.5 Adjustments to Awards
  • Grant Adjustment Notice
  • Prior Approval of Certain Costs
  • Reprogramming of Funds
• 3.6 Costs Requiring Prior Approval
  • Introduction
  • Responsibility for Prior Approval
  • Procedures for Requesting Prior Approval
  • Listing of Costs Requiring Prior Approval
• 3.7 Property Standards
  • General Principles for Property Acquisition and Management
  • Screening and Property Management Systems
  • Equipment Ownership, Use, Management, and Disposition
  • Equipment and Supplies Acquired With Grant Program Funds
  • Federal Equipment
  • Replacement of Equipment
  • Supplies
  • Real Property Acquired With Federal Funds
  • Retention of Property Records
  • Intangible Property
  • Copyrights
  • Data Produced Under A Federal Award
  • Patents, Patent Rights, and Inventions
• 3.8 Procurement under Awards of Federal Assistance
  • Procurement Standards—
    General Guidance
  • OJP Construction Requirements
• 3.9 Allowable Costs
  • Introduction
  • Compensation for Personal Services
  • Conferences and Workshops
  • Travel
  • Project Site
  • Printing
  • Publication
  • Duplication
  • Other Allowable Costs
• 3.10 Conference Approval, Planning, and Reporting
  • Introduction
  • Policy Overview
  • Definitions
  • No Prior Approval Required
  • Prior Approval Required
  • Event Planning Guidance
  • Conference Cost Categories
  • Post Event Reporting
  • FAQs
  • Resources
• 3.11 Indirect Costs
  • Introduction
  • Federal Indirect Cost Rate—Negotiated Agreements
  • Establishment of Indirect Cost Rates
  • Indirect Cost Distribution Bases
  • Cost Allocation Plans—Central Support Services
  • Lobbying Costs and the Indirect Cost Pool
  • No Approved Plan
  • Approval of Indirect Cost Rates for Subrecipients
• 3.12 OJP's Confidential Funds
  • Introduction
  • Approval Authorities
  • Confidential Funds Certification
  • Written Procedures
  • Informant Files
  • Regional Information Sharing Systems (RISS) Program
  • Accounting and Control Procedures
• 3.13 Unallowable Costs
  • Introduction
  • Unallowable Cost Categories
• 3.14 Subrecipient Management and Monitoring
  • Introduction
  • Subrecipient Monitoring
  • Best Practices
• 3.15 Reporting Requirements
  • Introduction
  • SF-425 Federal Financial Reports
  • Progress/Program Reports
  • Government Performance and Results Act
  • Reports Required under the Federal Funding Accountability and Transparency Act
• 3.16 Retention and Access Requirements for
  Records
  • Retention of Records
• 3.17 Remedies for Noncompliance
  • Introduction
  • Termination
  • Hearings and Appeals
  • Effects of Suspension and Termination
• 3.18 Closeout
  • Introduction
  • First Step
  • Closeout of Discretionary/
    Categorical and Block/Formula Awards
  • Refund of Federal Grant Monies and/or Program Income
  • Failure to Remit Funds Owed
• 3.19 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 2014)
  • Audit of Subrecipients
  • Technical Assistance
  • Full-Scope Auditing
  • Commercial (For-Profit) Organizations
  • Failure to Comply
  • Office of Inspector General Regional Offices
• 3.20 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
• 3.21 Payment Programs
  • Introduction
  • Bulletproof Vest Partnership
  • State Criminal Alien Assistance Program
  • Northern Border Prosecution Initiative and Southwest Border Prosecution Initiative

3.14 Subrecipient Management and Monitoring

Introduction

A subaward is an award made by a pass-through entity to a subrecipient for the purpose of carrying out a portion of the work funded by the pass-through entity???s Federal award. The pass-through entity may use any form of legal agreement for making a subaward, including an agreement that the pass-through entity considers a contract. A subaward is not a contract by which the non-federal entity (i.e., the recipient or a subrecipient) enters into an agreement with an entity to purchase property or services needed to carry out the project or program under a Federal award (see 2 C.F.R. ?? 200.22 (Contract).

In keeping with 2 C.F.R. ?? 200.330 (Subrecipient and Contractor Determinations), the following circumstances support classification of a non-federal entity as a subrecipient of the pass-through entity:

• The non-federal entity determines who is eligible to receive what Federal assistance;
• The non-federal entity???s performance is measured in relation to whether objectives of the Federal program were met;
• The non-federal entity has responsibility for programmatic decision making;
• The non-federal entity has responsibility for adhering to applicable program requirements under the Federal award; and
• The non-federal entity uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.

In contrast, a contract for the purpose of obtaining goods and services for the pass-through entity???s own use creates a procurement relationship with the contractor. Circumstances supporting this type of relationship include:

• The non-federal entity provides the goods and services within normal business operations;
• The non-federal entity provides similar goods or services to many different purchasers;
• The non-federal entity normally operates in a competitive environment;
• The non-federal entity provides goods or services that are ancillary to the operation of the Federal program; and
• The non-federal entity is not subject to the compliance requirements of the Federal program as a result of the agreement.

All of the characteristics listed above may not be present in all cases, so the pass-through entity must use judgment when categorizing each agreement as a subaward or a procurement contract.

The contract or other written agreement must not affect the recipient's overall responsibility and accountability to the Federal Government as the award recipient for the duration of the project. As the recipient of the award, you are responsible for monitoring the subrecipient and ascertaining that all fiscal and programmatic responsibilities are fulfilled.