Outcomes: Since the introduction of the new Uniform Guidance (UG) in 2014, USAID and HHS/CDC have been including the new requirements in their awards to Implementing Partners (IPs). The requirements can differ depending on whether an IP is local or US-based and also can differ by Agency. This highly interactive two-day course will quickly bring new or experienced finance, technical, compliance and audit staff up to date with the most recent interpretation of the UG rules. This course will put the current compliance environment into perspective and highlight how to efficiently manage a project or organization, whether at the Prime or Sub level. Conducted by a practicing CPA with over 37 years of hands-on USAID financial management, audit and compliance experience, this course is a must for organizations needing to ensure that their team members are operating in accordance with the current rules and regulations. Participants are welcome to bring their awards and audit reports to the course for confidential discussions.

Group-Live Offering
Basic: No Advance Preparation or Prerequisites Required; 16 CPE Hours






September 2 - 8:45 AM

September 3 - 5:30 PM

Lusaka, Zambia

Neelkanth Sarovar Premiere Hotel, Plot 6111, opp. Mandla Hill Mall, (Emerald room)

Doug Franke



High-Level Background on the Essentials of Financial Management and Compliance Including Objectives of the Uniform Guidance
  • Understanding the difference between Grants, Cooperative Agreements, Contracts and Fixed Amount Awards, including how a Prime Recipient can/should consider which mechanism to use for subs.
  • The fundamental principles of “Reasonable, Allocable, Allowable and Supported/Documented” must be understood or audit findings will result, and nobody wants those.
  • High-level discussion of the responsibilities of the various staff members within the USG, recipients and auditors (e.g., the Recipient Finance Staffer who sub-awards funds will become very busy!)
  • Overview of new risks based on Agency-specific interpretation of rules
  • Overview of Cost Principles
  • Overview of new USAID audit processes and oversight – Yellow Book 2020 update
  • Understanding how the UG applies differently to US and NON-US organizations – as well as by Agency
Detailed Review and Discussion of the Uniform Guidance (UG)
  • Section 200.100 (Subpart B -General Provisions) and 200.200 (Subpart C – Pre-Federal Award Requirements and Contents of Federal Award) are discussed to ensure participants understand how and why certain provisions are relevant to them. For example, there is a substantial amount of additional information which the USG puts into the prime awards, which primes must include in their sub-agreements, which, if not done, could result in unnecessary audit findings.
Detailed Review and Discussion of the New Section 200.300 (Subpart D - Post-Federal Award Requirements Standards for Financial and Program Management)
  • This section correlates with what had previously been covered in the 22 CFR 226/45CFR 74, as well as the USAID Mandatory Standard Provisions (for US and NON-US NGOs) and the HHS/Grants Policy Statement. There are substantial changes in this section including the following:
  • Agencies' Adoption of the 10% De Minimus and (High-level) Indirect Cost Rates
  • New Performance Measurement Requirements which will now require the technical and financial staff to work more closely together
  • New Internal Control Requirements
  • New Cost Share Rules
  • Financial Management Requirements
  • Subrecipient Monitoring and Management (possibly the most important change!)
  • New Procurement Rules
  • Program Income
  • Asset Management & Disposition
Detailed Review and Discussion of the new section 200.400 (Subpart E – Cost Principles)
  • This section covers how the three different sets of “old” cost principles (OMB A122, A21 and A87) have been consolidated into a single set and includes discussion of what principles have come out, been changed, and what is totally new
  • Discussion of the additional requirement for determining cost “reasonableness”
  • Clarification on the 22 areas where Prior Approvals by Federal Awarding Agencies may be necessary (at the Prime and Sub levels)
  • Pass-through entity (or Prime) cost allowability for managing subrecipients and limitations on what kind of organizations can do this
  • Timekeeping requirements
  • Travel rules and regulations
High-Level Discussion of the New Section 200.500 (Subpart F – Audit Requirements)
  • This section will cover how the old OMB A133 has been changed and what new rules have been put in place. It will cover the new thresholds and changes in the levels of materiality.
  • Discussion of how auditors may need/wish to change their audit programs and considerations of risk
  • Discussion of what level of review/oversight must/should a Prime obtain over their subs.
Discussion of the Applicability for Different Types of Organizations of the 11 UG Appendices Detailed discussion of the USAID Mandatory Standard Provisions (MSPs)for NON-US NGOs
  • We begin by understanding the difference between the MSPs for US, NON-US and Fixed Amount Awards scenarios
  • Detailed walk though and discussions of the most relevant MSPs and where non compliance frequently leads to audit findings, for such things as Revisions to Budgets, Procurement Policies, Title to Property Termination and Suspension, Construction Activities, Whistleblowing, the Mexico City Policy, etc.
  • Walk through of the most relevant Required As Applicable Standard Provisions such as Advance Payments, NICRA versus direct costing or Indirect Costs charged as a Fixed Amount, Subawards, International Travel, Patent Rights, Recipient Integrity and Performance Matters, etc.
Detailed discussion of the 2 CFR 200.400 section on Cost Principles
  • Refresh on the concepts of “Reasonable, Allocable, Allowable and Supported/Documented, and Credits.
  • Further discussion of rule around Prior Approvals
  • High-level discussion of Direct Costs
  • High-level discussion of Indirect Cost
  • Discussion of where the 10% de minimis (for USAID) and 8% de minimis for HHS/CDC can be elected.
  • Walk through of the most important cost principles where IPs get things wrong and audit findings result
Detailed discussion of Audit-Related Issues
  • What is the state of play of the transition of auditor selection, auditor rotation, quality oversight, etc. from the OIG to USAID Missions
  • Review of most recent Guidelines for contracting for and conducting a Recipient Contracted Audit, including newest USAID Statement of Work
  • Discussion of how to select a competent auditor and what to watch out for
  • How to work with your auditor for an efficient and effective audit that will result in a GAGAS-compliant report
Throughout the entire course, participants are welcome to ask questions to clear-up any issues or concerns.


Agenda TBA

Venue and hotel

Neelkanth Sarovar Premiere Hotel, Plot 6111, opp. Mandla Hill Mall, Lusaka Zambia (Emerald room)


CPE Credit

SustainAbility Solutions is registered with the Michigan Association of Certified Public Accountants (MACPA) which is a sponsor of continuing professional education credits. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit and SustainAbility Solutions works with the MACPA to ensure that it's courses and trainers meet the high Michigan standards. Complaints regarding our courses may be submitted to

Payment Policy

Payments for all participants must be made before the first day of the course. Individuals and companies/organizations have three different methods of payment: credit card, check (drawn on a US bank) or wire transfer. When you register through our on-line form you should indicate which payment method you prefer and we will send you the appropriate payment instructions. If you wish to register multiple participants or if you are signing up for more than one course in a week then discounts may apply. See below.

Cancellation/No Show Rules

Cancellation notifications received in writing to within 10 working days before the first day of any course will be eligible for a full credit to a future course. Registrants who cancel between 10 working days and the first day of the course will receive a credit of the fee paid less a $75 cancellation penalty. This fee will go to covering some of the costs that will have been incurred for the pre-booked venue. Registrants who do not show up for the course, without prior notification, will forfeit the full registration fee.

Group Discounts

Individuals or groups that sign up for more than two courses during the year are offered a 10% discount. Also, organizations that sign up more than three participants for any individual course can also earn a 10% discount. To receive the discounts you must register all participants at the same time and receive confirmation of this arrangement with our registration staff.

If you have any questions about our policies please send us an email as noted on the Contact Us tab.

Visas and Vaccination

Remember to apply for any visit visas early and to bring the Yellow Travel Card showing proof of vaccination if necessary.