If your organization receives federal grants and enters into agreements with subrecipients or contractors, it is critical that the substance of the relationship with each is fully understood. This is crucial for several reasons but the primary reason is that it is required (see Uniform Guidance – 2 CFR 200.332 – Requirements for pass-through entities).Continue reading “Understanding Subrecipient vs. Contractor Determination”
Category Archives: Requirements
A Summary of OMB Memorandum M-21-20
OMB Memorandum M-21-20 was broken into five sections that either underscore the federal government’s need for a swift response to the public health crisis, outline its commitment to accountability and transparency of ARP spending, or ensure that all Americans are supported through the advancement of racial equity and that underserved communities are supported.
A Summary of Appendix 3 of OMB Memorandum M-21-20
On March 19, 2021, the Office of Management and Budget (OMB) published Memorandum M-21-20 to outline the Administration’s approach to “effective implementation and stewardship of American Rescue Plan funds.” This post will summarize the twelve flexibilities outlined in Appendix 3.