Federal Grants Training & FAQ

Grants.gov is a central resource for finding and applying for federal grants. You can search by keyword, agency, or category. In addition, individual federal agencies often have their websites or portals dedicated to grant opportunities.

The Super Circular, formally known as the Uniform Guidance (2 CFR 200), is a set of regulations governing the administration of federal grants. It aims to streamline and standardize the grant process across different federal agencies. The Uniform Guidance covers various aspects, including:

• Definitions and Acronyms: Providing clear and consistent terminology for grant administration.
• General Provisions: Outlining overarching rules applicable to all federal awards.
• Post-Award Requirements: Detailing requirements for subrecipient monitoring, procurement, accounting, and internal controls.
• Cost Principles: Defining allowable and unallowable costs for federal awards.
• Audit Requirements: Setting standards for single audits and program-specific audits.

• Understand the Regulations: Familiarize yourself with the Uniform Guidance and any agency-specific supplements relevant to your grant.
• Develop Strong Internal Controls: Implement effective accounting systems, procurement procedures, and subrecipient monitoring processes aligned with the Uniform Guidance requirements.
• Document Everything: Maintain comprehensive records to support all your grant-related activities and cost allocations.
• Seek Expert Guidance: Consult with experienced grant professionals or legal counsel when needed.

A subrecipient is a non-federal entity that receives a subaward from the primary recipient of a federal grant to carry out a portion of the grant program. As a pass-through entity, you are responsible for:

• Determining Subrecipient vs. Contractor: Carefully assess whether the entity receiving funds meets the criteria of a subrecipient or a contractor.
• Flow Down Requirements: Ensure that all applicable Super Circular provisions and grant terms are flowed down to the subrecipient.
• Monitoring and Oversight: Establish a risk-based subrecipient monitoring program to assess compliance, review financial reports, and address any deficiencies.

• Mischarging Costs: Improperly allocating personal expenses as business expenses or charging unallowable costs to the grant.
• Timekeeping and Effort Reporting: Inaccurate recording of time spent on grant activities or allocating effort to the wrong projects.
• Procurement Violations: Failing to follow the procurement standards outlined in the Uniform Guidance, such as not obtaining competitive bids or properly documenting sole-source justifications.
• Conflicts of Interest: Engaging in activities that create a conflict of interest, such as awarding subgrants to entities with close personal or financial ties to the recipient.

• Develop Robust Policies and Procedures: Establish clear written policies and procedures covering all aspects of grant administration, including procurement, timekeeping, effort reporting, and subrecipient monitoring.
• Provide Training: Train staff members responsible for grant management on Uniform Guidance requirements and best practices.
• Conduct Regular Internal Reviews: Implement a system of internal reviews or audits to proactively identify and address potential compliance issues.
• Establish a Whistleblower Hotline: Encourage employees to report any suspected fraud or misconduct related to grant activities.
• Seek Legal Counsel: Consult with an attorney experienced in government contracts and grants to address any complex legal issues.

Non-compliance can lead to various penalties, including:

• Suspension or Debarment: Exclusion from receiving future federal awards.
• Disallowance of Costs: The government may refuse to reimburse unallowable costs, requiring the recipient to repay funds.
• Termination of Award: The awarding agency may terminate the grant entirely.
• Civil or Criminal Penalties: Fraudulent activity can result in substantial fines, imprisonment, or both.