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; Sub-recipient management AND Conflict of Interest/Fraud/Ethics.) 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 40 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.

Group Internet-based Offering (live online webinar)
Basic: No Advance Preparation or Prerequisites Required;
CPE Credit Hours: 8 CPE Hours as follows: 4.5 Accounting (Govt); 1.5 Auditing (Govt); 2 Regulatory Ethics (Tech)





Day1: July 24: 3:00PM-5:00PM (SAST)
Day2: July 25: 10:00AM-5:00PM (SAST) With two 30-minute breaks


Live online webinar

Doug Franke



Module 1
The 10% de minimis and NICRAs

This module will expand your knowledge about what auditors’ clients might try to do maximize their cost recovery. While all agencies are not yet allowing NICRAs for non-US organizations, this situation might change, and you should be ready. In addition, the CDC is beginning to allow an 8% indirect cost recovery for non-US-based organizations. There might be some unique cost allocation issues to consider. The US State Department (DOS) is allowing the 10% de minimis, but we have seen errors in the calculation of the MTDC base.

Module 2

This module gets to the point about how a project must be finalized. Auditors and recipients need to know what the compliance deadlines are as well as what costs will be allowed or disallowed. Our experience is that too many recipients end up paying back incurred expenses simply because they did not understand the close-out rules and/or confirm their plans with their Agreement Officers/GMOs.

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
The new “Green Book” requirements

This module focuses on internal controls and gives participants a high-level overview of the Globally accepted Internal Control Framework (COSO) which applies to all US Government implementing partners. While every organization - from NGOs to audit firms to listed companies, etc. needs internal controls, this module highlights the fact that every organization will have different controls based on its management structure, objectives, risk profile, and stakeholder reporting requirements. This module explains different internal control environments and discusses why every internal control system may be different.

Module 4
Sub-recipient Management, Sub-Agreement Preparation and Sub-Auditing

For auditors, if your client is a prime recipient, with sub-recipients, your client has significant responsibilities which are subject to audit. This module will discuss how to navigate complex situations such as when another audit firm is conducting the sub-recipient audit and your firm is auditing the prime recipient and vice versa.

For recipients, this module expands upon a lot of important USG requirements where we believe the current USAID guidance (Mandatory Standard Provision RAAP 8 – Subawards) does not really go far enough to explain what is necessary. This module makes it clear about what we believe is necessary to manage subrecipients and protect prime recipients from unnecessary audit findings.

Module 5
Ethics/Conflict of Interest/Fraud

The Uniform Guidance has specific rules on these. This module covers areas of compliance, as well as methods about how to prevent breaches of ethics, conflict of interest and/or fraud from occurring in the first place. Compliance is critical and auditors are expected to be aware of any situations where fraud could take place.

Suspension and termination of your clients can occur if they do not comply.

Participants are welcome to ask questions to clear-up any issues or concerns during the Q&A sessions which are held throughout the course.


Agenda TBA

Venue and hotel

Group Internet-based Offering (live online webinar)


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.