6 Reasons to Implement Powerful SaaS Budgeting Software
SaaS budgeting software helps public sector organizations improve the budgeting process by...
I was recently speaking with a client that received two federal grants from two different federal agencies. They began working on the contractor agreements for their vendors, and realized that each agency interpreted 2 CFR 200 (Uniform Grant Guidance or UGG) subaward vs. subrecipient vs. subcontractor terminology very differently.
This not only is confusing from an operations standpoint, but can have immediate implications from a transparency perspective if the application is not standardized across the board. Let’s start out with some definitions.
Real-life application: A subaward in this context refers to the actual contractual agreement between grant recipient and subrecipient, and not the name referred to the party receiving the contract.
Real-life application: In order to receive a subrecipient designation, the subrecipient must be performing tasks or deliverables that adhere to the work as identified in the application work plan.
Real-life application: In order to receive a subcontractor designation, the subcontractor/ contractor/ vendor (terms used synonymously) must provide ancillary or advisory support that is not integral to the actual completion of workplan deliverables as identified in the application.
This can be very confusing, especially as you develop contracts and determine how to apply these terms. What are the implications of these designations?
According to §200.68 Modified Total Direct Cost (MTDC), all direct salaries and wages, applicable fringe benefits, materials and supplies, services, travel, and up to the first $25,000 of each subaward (regardless of the period of performance of the subawards under the award) can be counted towards indirect costs. However, I have seen this applied toward subcontracts and subrecipients, even though UGG clearly states that a subaward is intended for subrecipients.
Lucy Morgan is an excellent coach and provides training on all topics related to federal grant recipients and implications in the sector. In addition, the Association of Government Auditors (AGA) released a handy Subrecipient Monitoring and Self-Assessment Guide in November 2017.
Founder of RBW Strategy, Rachel Werner spent nearly seven years as a dedicated fundraiser and grant writer for nonprofit organizations and freelance clients. She has served as a dedicated fundraiser and grant writer for nonprofit organizations and as a grants management specialist implementing a compliance system for large U.S. Department of Education No Child Left Behind funds within charter schools across the U.S. In addition to being a skilled project manager, she has strong subject matter expertise pertaining to the grants lifecycle.
(Editor’s note: This post was updated on May 1, 2018)