How the new 10% De minimis Environment will Affect You
Understanding NICRAs and Your Options
USAID is still in the process of interpreting exactly how to implement some of their rule changes for non- US organizations. In certain circumstances, both Prime and Sub-Recipients may be able to obtain a NICRA or Negotiated Indirect Cost Rate Agreement (or “Overhead Rate”). This is a fairly complicated exercise. This module will give you the high-level understanding you need to understand to calculate your Prime rate or review your sub-recipient’s submission to you as the Prime Recipient.
This module will also equip you with the information you need to understand every recipient organization’s right to the new 10% de minimis under CFR 200.414 (f). You will also participate in a practical exercise of how to transition to the 10% environment. (NB – CDC has an 8% allowance).
The module will also give you an understanding of how to create a written policy statement that clearly outlines which costs are direct and which are indirect as well as guidelines to support these costs. This module will equip you to prepare your own or review another organization’s Cost Policy Statement.
The Importance of Understanding the Close-out Process Procedures to Avoid Unexpected Consequences
Starting a project receives much more attention and fanfare than closing out a project. However, closing out a USG project is a crucial process and is just as important, if not more important, than starting a project. The key difference is that the kick-off a project can be more of an event and the close out is more of a process. The process need to be completely understood, planned for and implemented properly in order to prevent negative consequences.
Planning ahead is critical. The close out process can take up to 6 months to complete before the actual project end date. If you are not fully aware of the USG rules, some of your close-out costs might be disallowed.
Learn the 7 Essential Aspects of the Close-out Process
This section explains everything you need to know about:
- Human Resources
- Public Relations
Internal Control – “Green Book” Requirements
Essential Compliance Guidance to Safeguard your Organization
Yellow Book auditors frequently cite poor internal controls as the “criteria” for negative audit findings. Internal audit is required is according to the “Green Book” – the US Government Standards for Internal Control in the Federal Government.
The requirements, at 2 CFR 200.303 of the Uniform Guidance require that all recipients of US Government funding have an internal control system that should be compliant with the “Green Book”. This module is crucial for all finance personnel, compliance officers and M&E officers as well as those responsible for monitoring of the internal control systems (e.g., directors, internal and external auditors). The module will provide a mid-level overview of the Green Book and provide guidance on how to competently implement the Green Book within the organization to safeguard it from negative findings.
Understanding Conflict of Interest/Fraud/Ethics
Preventing Reputational Damage
If not properly managed, fraud, conflicts of interest and unethical practices may all ultimately lead to an organization’s reputational damage. Management and auditors are all responsible, to varying degrees, for reporting fraud, breaches of ethics and conflicts of interests.
This module will guide non-federal entity management in understanding their obligations and fiduciary responsibilities in the prevention and detection of fraud, conflict of interest and ethics violations, including requirements for fraud reporting (2 CFR 200.113 & 45 CFR 75.113), entity conflict of interest management (2 CFR 200.112 & 45 CFR 75.112) and management of conflict of interest by employees in procurement (2CFR 200.318(c)(1) & 45 CFR 75.327(c)(1). This module will also help auditors assess the impact of conflict of interest and ethics violations, and the resulting risk of fraud being committed.
Finally, the module covers the reporting of fraud, as required by the Government Auditing Standards and the OIG Guidelines for Financial Audits Contracted by Foreign Recipients.
Sub-Recipient Management, Sub-Agreement Preparation and Sub-Auditing
Understanding the Differences between a Sub-Award and a Fixed Amount Award
How well do you know the different US Government funding mechanisms? Do you know which vehicle should be used for what? An organization may concurrently receive donor funding as a recipient, a sub-recipient, and a contractor, depending on the purpose of the funding and the substance of its agreements with Federal awarding agencies and pass-through entities. The most common form of funding for NGOs is a Cooperative Agreement and then if there are sub partners, they normally receive a sub-award.
This module provides a deep dive into the requirements of 2 CFR 200.331:
Requirements for pass-through entities, including the required information for a sub-award agreement, how to perform and evaluate the pass-through entity’s risk assessment procedures prior to the subaward and what is required in terms of adequate sub-recipient monitoring. The module will also address the differences between a sub-award and a Fixed Amount Awards and provide guidance on what type of award should be used in different circumstances.