2 C.F.R. Uniform Guidance: Subpart C (1 of 2)

Compliance is critical to the grants world. To create a 21st century government that is efficient, effective, and transparent - OMB's final guidance improves performance, transparency, and oversight for Federal awards. It is must that the Federal awarding agencies and the recipients abide by the regulations, policies and procedures. In this blog post, we will go over Subpart C and understand what it all entails. Are you ready?? Here we go.........

What is Subpart C??
The Pre-Federal Award Requirements and Contents of Federal Awards. It includes Sections 200.200 thru 200.213. Below is the list of sections in Subpart C: 

200.200  Purpose.

200.201  Use of grant agreements (including fixed amount awards), cooperative agreements, and contracts.

200.202  Requirement to provide public notice of Federal financial assistance programs.

200.203  Notices of funding opportunities.

200.204  Federal awarding agency review of merit of proposals.

200.205  Federal awarding agency review of risk posed by applicants.

200.206  Standard application requirements.

200.207  Specific conditions.

200.208  Certifications and representations.

200.209  Pre-award costs.

200.210  Information contained in a Federal award.

200.211  Public access to Federal award information.

200.212  Reporting a determination that a non-Federal entity is not qualified for a Federal award.

200.213  Suspension and debarment. 

Let's go in depth to understand each section so you can make better decisions on grant research and grant writing. 

200.201 Use of grant agreements (including fixed amount awards), cooperative agreements, and contracts

(a) The federal awarding agency or pass-through entity must decide on grant agreement, cooperative agreement or contract. 

(b) Fixed Amount Awards are allowed; this is new. Now, you ask what's fixed amount. In Subpart A definition is 200.45 a type of grant agreement under which the Federal awarding agency or pass-through entity provides a specific level of support without regard to actual costs incurred under the Federal award.

1.  By meeting specific requirements, payments will be determined. Accountability is based on performance and results. The Federal award amount is negotiated using the cost principles except if the award was terminated. With assurance that the non-Federal entity will realize no increment above actual cost--the Federal agency or pass-through entity may use fixed awards. 

2. Programs that require mandatory cost sharing or match cannot use fixed amount award. 

3. The grant recipient must notify the awarding agency in writing that completed project or the expended effort. Federal award must be adjusted, if the required level of effort was not carried out. 

4. You MUST receive prior written approval from the Federal agency or pass-through entity for changes in principal investigator, project leader, project partners or project scope. 

200.202 Requirements to provide public notice of federal financial assistance programs

(a) The Federal awarding agency must notify the public of Federal programs on Catalog of Federal Domestic Assistance (CFDA). 

1. The executive branch of the Federal government has designated CFDA as the single, authoritative government-wide comprehensive source of Federal financial assistance program.
2. In order to award Federal financial assistance, the Federal awarding agency must assign the funding to a program that has been included in CFDA.

(b) The Federal agency must submit the following information to GSA for any awards: 

1. Program Description, Purpose, Goals and Measurements.
   Summary of the statutory or regulatory requirements of the program. 
   Program Description, Purpose, Goals & Measurement should align with strategic goals and objectives within the Federal awarding agency's performance plan and should support the Federal awarding agency's performance measurement management & reporting. 
2. Identification of Federal awards (discretionary basis, formula)
3. Projected total amount of funds available for the program. 
4. Anticipated Source of Available Funds: This includes the statutory authority for funding the program, Federal agency, sub-agency, or if known the specific program unit that will issue the Federal awards. 
5. General Eligibility Requirements-All statutory, regulatory, or other eligibility factors that determine the applicant's qualifications for Federal awards. 
6. Applicability of Single Audit as required by Subpart F. 

200.203  Notices of funding opportunities

Competitive grants and cooperative agreements require that the Federal agency must announce specific funding opportunities in a public notice: 

  (a) Summary Information in Notices of Funding Opportunities:. The following information must be posted the following information: 

1. Federal Awarding Agency Name 
2. Funding Opportunity Title 
3. Announcement Type (whether the funding opportunity is the initial announcement of this funding opportunity or a modification of a previously announced opportunity.) 
4. Funding Opportunity Number is required if applicable
5. Catalog of Federal Financial Assistance (CFDA) Number 
6. Key Dates include due dates for application

(b) Full Text of Funding Opportunities: The following information must be included in the full text of each funding opportunity. 

1. Full programmatic description of the funding opportunity 
2. Federal award information including sufficient information to help an applicant make an informed decision about whether to submit an application. 
3. Specific eligibility information including any factor's or priorities that affect an applicant's or application's eligibility for selection.
4. Application Preparation and Submission Information, including the applicable submission dates and times. 
5. Application Review Information including the criteria and process to be used to evaluate applications. 

200.204 Federal awarding agency review of merit of proposals

Unless it is prohibited by Federal statues, the Federal awarding agency must design and carry out a merit review process for applications for competitive grants or cooperative agreements. This action must be specified in the funding opportunity. 

200.205  Federal awarding agency review of risk posed by applicants.

(a) Per statues 31 U.S.C. 3321 and 41 U.S.C. 2313 the Federal awarding agency must review the eligibility qualification or financial integrity performance. For example: Federal Awardee Performance and Integrity Information System (FAPIIS), Dun and Bradstreet, and "Do Not Pay". 

(b) A framework for evaluating the risks posed by applicants before they received federal funding is must for competitive grants or cooperative agreements. 

200.206  Standard application requirements.

(a) Paperwork clearances. The Federal agency may only use application information collections approved by OMB under the Paperwork Reduction Act of 1995 and Controlling Paperwork Burdens on the Public. OMB authorizes additional information collection on limited basis.

I hope this post will help you understand the Subpart C; this should guide you on the roles of the Federal awarding agency and what you should expect from the opportunities that get posted on Grants.gov 

We will cover the section 200.207 thru 200.213 of Subpart C in my next blog post. This was getting way to lengthy and I believe you will benefit more if I break it into sections. I would love to hear from you, please share your comments below. Thank you