Grantees

Clarify Risk Analyses for Subrecipients Under Uniform Guidance

OMB should clarify the parameters for the risk analyses that universities are required to make for their subrecipients under the Uniform Guidance. Such a move would help to curtail the proliferation of individualized standards or action plans established by individual universities seeking to carry out their responsibilities under the as prime recipients with respect to their subrecipients.

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Grantees

General comment

I am surprised more people haven't been commenting or making suggestions. Do you think it might be due to the fact that most of us are so busy with our jobs, lacking funds, burnt out and trying to pick up pieces of pie because we are spending our own time working and ignoring everything else? Our jobs have become so complicated with reporting and regulations that we don't have time to take care of the people and partners ...more »

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Contractors and Grantees

This dialogue is not a pilot program.

Section 5 of the DATA Act of 2014 requires the Office of Management and Budget (OMB) to establish a pilot program to test whether standardizing the data elements used in recipient reporting can reduce the burden that grantees and contractors experience in reporting on the federal funds that they receive and spend. In this fiscal year, federal agencies have awarded $540 billion in grants and $297 billion in contracts. ...more »

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Grantees

Eliminate Subcontracting from Prime Awardees

Grant Proposals indicate all institutions involved and require separate budget submissions. Not only is it a waste of taxpayer $ to pay institutions F&A on the first 25K of each sub, but it is so inefficient to dole out the $ to us to turn around and pay out the subs when you can utilize a LOC payment system. Then you impose subrecipient monitoring on us and everybody has to document everyone else's audit report/FCOI ...more »

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Grantees

Change in Modified Total Direct Costs

Currently Modified Total Direct Cost (MTDC) only allows inclusion of subcontracts up to the first $25,000 of each subaward or subcontract (regardless of the period of performance of the subawards and subcontracts under the award). We suggest increasing this to the first $50,000.

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Grantees

Raise the Questioned Cost Threshold Above $25,000

The OMB Compliance Supplement for the Single Audit increased the threshold for known or likely questioned costs from $10,000 to $25,000. Princeton University suggests that consideration should be given for a threshold higher than $25,000, particularly when extrapolation could occur throughout the rest of the organization. An alternative solution would be to make the threshold related to a percentage of expenditures ...more »

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10 votes
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Contractors

Recommendations from The Coalition for Government Procurement

Last year, the Coalition for Government Procurement submitted a number of recommendations in response to the Chief Acquisition Officers Council (CAO) Council Open Dialogue to improve the economy and efficiency of the Federal acquisition system. The Coalition urges the government to take action on the previously submitted recommendations to increase the efficiency and the effectiveness of Federal procurement. Implementing ...more »

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9 votes
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