Course Outline:
Understanding and Preparing for the Termination Settlement Process (TSP)
Many Implementing Partners and Contractors have received Stop Work Orders, and then Termination notices.
Unfortunately, there is not a lot of guidance on the Cooperative Agreement or Grant side ofthe USG.
This session will take you through the important things that terminated partners need to understand to achieve maximum recovery of incurred costs. The good news is that all reasonable costs (accounting and legal) incurred in preparing the TSP will be allowable.
Understanding NICRA and the New 15% Environment
- While USAID is still interpreting exactly how to implement some of these rule changes for non-US organizations, it would appear that in certain circumstances, both Prime and Subrecipients may be able to obtain a NICRA or Negotiated Indirect Cost Rate Agreement (or “Overhead Rate”) which is a fairly complicated exercise.
- Understanding, at a high level, the processes for calculating your (Prime) rate or reviewing your sub-recipient’s submission to you as the Prime Recipient. Consideration of the new 15% de minimis options (under 2 CFR 200.414 (f)) and whether it even makes sense to apply for a NICRA, if offered.
- How to prepare or review an organization’s Cost Policy Statement, which is a written policy that outlines the costs considered as direct, the costs considered to be indirect, and the rationale to support those costs.
- Exercise to practice preparing a 15% de minimis Modified total direct cost (MTDC).
Internal Controls/Green Book Summary
- Overview of the new 2 CFR 200.303 section on Internal Controls or the “Green Book” and guidance on how to competently implement the Green Book within the organization to safeguard it from poor internal controls which might lead to fraud and negative audit findings. Many practical examples are discussed to bring internal controls to life.
- Sub-recipient management; sub agreement preparation (very light) and sub auditing
- An organisation may concurrently receive donor funding as a recipient, a sub-recipient, and a contractor, depending on the substance of its agreements with Federal -Awarding Agencies and pass-through entities.
- A sub-award is for the purpose of carrying out a portion of a Federal award and creates a Federal assistance relationship with the sub-recipient.
- Requirements of 2 CFR 200.332: 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 sub-award and what is required in terms of adequate sub-recipient monitoring.
- 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.
Conflict of Interest/Fraud/Ethics
- Fraud, conflicts of interest and unethical practices may all ultimately lead to an organization’s reputational damage if not properly managed.
- Management and Auditors have varying levels of responsibility in managing and reporting related to fraud, ethics and conflicts of interest.
- Ethics and conflict of interest violations can result in fraud being committed.
- Assisting of non-federal entity management in understanding their obligations 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).
- Assessing the impact of conflict of interest and ethics violations, and the
resulting risk of fraud being committed.
Reporting of fraud, as required by the Government Auditing Standards and the OIG Guidelines for financial audits contracted by
foreign recipients.
Participants are welcome to ask questions to clear-up any issues or concerns during the Q&A sessions which are held throughout the course
Day 1:
Day 2:
Participants are required to attend both days to receive credits.
SustainAbility Solutions PC is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website: www.nasbaregistry.org
