Outcomes: Managing USAID and CDC projects comes with many challenges and this course focusses on five areas where additional understanding is essential. (i.e., 10% de minimis/NICRAs; Close-out; Internal Controls; Conflict of Interest/Fraud/Ethics; and Sub-recipient management.) The five modules in this course are tailored versions of half or full day courses, and the most important parts will be covered to ensure that participants are aware of their compliance and/or audit responsibilities. Conducted by a practicing CPA with over 37 years of hands-on USAID financial management, audit and compliance experience, this course will learn from the mistakes (anonymous) that other organizations have made and should result in better program performance and compliant financial management. 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; 8 CPE Hours






September 20 - 8:45 AM

September 20 - 5:30 PM

Abuja, Nigeria

Bolton White Hotel, 7 Gwandu Street, Opposite Sahad Stores, Area 11, Garki 2

Doug Franke



Module 1
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 how 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.

Module 2
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:

  • Management
  • Programmatic
  • Human Resources
  • Financial
  • Legal
  • Logistics
  • Public Relations
Module 3
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 controls are required in accordance with 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 state that all recipients of US Government funding should have an internal control system that is 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.

Module 4
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.

Module 5
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.


Agenda TBA

Venue and hotel

Bolton White Hotel, 7 Gwandu Street, Opposite Sahad Stores, Area 11, Garki 2, Abuja, Nigeria


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.