(The following was excerpted from a recent article in the Federal Grants Management Handbook.) The Office of Management and Budget’s (OMB’s) uniform grant guidance requires federal agencies and pass-through entities to clearly define the intended performance outcomes of recipients and subrecipients. Speaking recently to attendees at the Council for Resource Development’s (CRD’s) annual conference in Washington, D.C., Toni DeMaglio, coordinator of grants support and effectiveness at Seminole State College in Sanford, Fla., stressed the importance of this provision when a pass-through partners with other entities.
In the terms and conditions of a federal award, the awarding agency must include an indication of the timing and scope of expected performance by the nonfederal entity as related to the outcomes intended to be achieved by the program (§200.210(d)). Where appropriate, the federal award may include specific performance goals, indicators, milestones or expected outcomes with an expected timeline for accomplishment. Under the flow-down provisions in Subpart B of the uniform guidance (§200.101(b)(1)), pass-through entities should also include information about performance goals in their subawards.
DeMaglio suggested that prime recipients provide clear expectations for subrecipients, as defined in the subrecipient agreement. Moreover, they should avoid changing a subrecipient’s performance goals after the award is made. “Don’t be the prime that surprises,” she said. “If it’s not in the agreement, don’t expect it, and don’t be surprised when the subrecipient is not excited about embracing the change. No one likes the bait and switch approach to grants management. Unless you have a reason to require additional burdens on your subrecipient, don’t do it.”
During a session on grant partnerships, DeMaglio offered advice to help community college administrators develop better relationships with subrecipient partners, although her suggestions could be heeded by all pass-through entities. As a general word of caution, she urged organizations that plan to become pass-through entities to fully understand their requirements, which are covered in Subpart D §§200.330-200.332 and Subpart B §200.101(b)(1) of the uniform guidance, and determine whether they can meet those responsibilities. “If your college is not ready to accept the management challenges, or does not have the capacity to serve as the prime recipient on the project, do whatever you can to have your voice heard,” she advised. “Assist your senior team to understand the risk of serving as the prime recipient.”
(The full version of this story has now been made available to all for a limited time on Thompson’s Grants Compliance Expert site).
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