Financial Assistance Applicants and Indirect Cost Rates Overview
Now that we have covered revisions to performance measurement, program design, de minimis indirect cost rate, terminology, closeout time, purchase thresholds, period of performance and budget period, data, and risk management in the Guidance for Grants and Agreements, we are wrapping up our blog series by detailing the new requirements for financial assistance applicants and various changes to indirect cost rates.
Read on to learn about the last few revisions to this Guidance.
Addition of FAPIIS Requirement
For those who are financial assistance applicants, in this updated guidance the OMB now requires you to provide information in SAM regarding your immediate business and highest-level owner and subsidiaries, as well as on all predecessors who have been awarded a Federal contract, grant, or cooperative agreement within the last three years. Also, prior to making a grant or cooperative agreement, the OMB now requires agencies to consider all of an applicant’s immediate owner or highest-level owner information that appears in the Federal Awardee Performance and Integrity Information System (FAPIIS), if applicable.
Changes to Indirect Cost Rates
The OMB has also clarified in this Guidance the responsibilities of pass-through entities in regards to establishing sub-recipient indirect cost rates and to resolving sub-recipients’ audit findings. Specifically, pass-through entities cannot require the use of the 10 percent de minimis indirect cost rate if the recipient already has a Federally approved indirect cost rate established.
Also, to support post-award compliance, per this Guidance, the OMB now requires any indirect cost rates and structures be made public.
Lastly, effective immediately, the OMB has placed restrictions on indirect costs of certain telecommunications services or equipment.
How to Prepare for Compliance With These Changes
As with all of the changes we have covered in this blog series, you can best maintain compliance with these revisions by using a centralized system that allows you to automate your grant management processes. For example, when creating applications in AmpliFund, organizations working with financial assistance applicants can specify what information they need to provide, such as owner information.
Also, whatever system your organization employs should give you the ability to collect multiple pieces of information related to indirect costs so your organization can comply with the new indirect cost revisions. With AmpliFund’s standard opportunity details form, you can collect indirect cost information such as description, rates, restrictions, and citations governing restrictions. You can publish this information on each opportunity.
The full version OMB’s updated Guidance for Grants and Agreements can be accessed here.
Just because we have finalized this series does not mean we will stop answering questions on this Guidance or other grant-related topics. If you have further questions, comment them on this post or reach out to us directly.
All editions of this series are now available on our blog:
Image source: Dylan Gillis