manage-post-award-compliance-and-reporting

name

manage-post-award-compliance-and-reporting

description

Keep an awarded federal grant clean from setup through closeout — run the 2 CFR 200 cost-principle test (allowable/allocable/reasonable) on every charge, establish and apply the indirect rate (NICRA vs de minimis on MTDC), keep time & effort certified, produce the SF-425 FFR and the RPPR/SF-PPR on the award calendar, make the 2 CFR 200.331 subrecipient-vs-contractor determination and stand up subrecipient monitoring, and carry the award to an audit-ready closeout (Single Audit threshold, documentation trail, final reports). Reach for this when the user asks "can we charge this cost?", "what indirect rate?", "build the FFR/RPPR", "subrecipient or contractor?", or "are we audit-ready?". Used by `grants-compliance-and-reporting-specialist` (primary). Not legal/accounting advice.

Skill: manage-post-award-compliance-and-reporting

Invoked by: grants-compliance-and-reporting-specialist (primary). Also consulted by grants-strategy-lead to confirm a proposal-stage commitment (indirect rate, subrecipient plan) is deliverable before it becomes binding.

When to invoke: "Can we charge this cost to the grant?"; "what indirect rate can we charge?"; "build the FFR / RPPR"; "is this partner a subrecipient or a contractor?"; "are we audit-ready?"; "set up the compliance calendar / run closeout"; any post-award compliance or reporting move.

Output: a cost-principle test, or an indirect-rate path, or the FFR/RPPR, or a subrecipient determination + monitoring plan + audit-readiness check — each cited, retrieval-dated, and captured in the compliance tracker. Not legal/accounting advice.

Procedure

1. Anchor the award terms first. Capture the Assistance Listing/CFDA number, period of performance, total + indirect terms, cost-share/match, reporting cadence, and program-specific terms into ../../templates/post-award-compliance-tracker.md. Compliance starts at setup, not the first report.
2. Run the cost-principle test on every charge in question. Under 2 CFR 200 Subpart E a federal cost must be allowable (permitted by the cost principles + the award; some costs are expressly unallowable), allocable (benefits the award in proportion charged), and reasonable (a prudent person would incur it). "We budgeted it" is not the test — document the rationale and cite the section (retrieval-dated). See ../../knowledge/grants-management-patterns-2026.md.
3. Establish the indirect rate before charging indirect. Use a negotiated NICRA if one exists; otherwise the de minimis rate on Modified Total Direct Costs (MTDC) — historically 10%, raised by recent Uniform Guidance revisions (widely reported up to 15%) → verify the current rate + effective date against eCFR before applying. Apply to the correct base (MTDC excludes equipment, capital, the over-threshold portion of each subaward).
4. Keep time & effort defensible. Payroll charged to the award must be supported by records of actual work, certified after the fact — the single most-cited audit finding area. Set up the certification cadence now; never reconstruct effort from memory at year-end.
5. Make the subrecipient-vs-contractor determination on substance. Apply the five 2 CFR 200.331 characteristics (see the decision-tree doc) — a subrecipient carries out the program and is subject to compliance; a contractor provides goods/services in a competitive market. A subaward triggers monitoring (2 CFR 200.332: risk assessment, required flow-down terms, reviewing their reports, verifying their Single Audit, following up on findings); a contract triggers procurement standards. Document the call.
6. Report on the calendar, from the tracker. Build the SF-425 FFR (financial) and the RPPR / SF-PPR (performance) to the award's cadence, figures traced to the ledger. Track drawdowns against the period of performance and the advance/reimbursement method. A missed report jeopardizes the current draw and the next award.
7. Stay audit-ready and close out. Watch the Single Audit threshold (≥ the current figure in federal awards expended in a fiscal year — long $750K, recently raised, widely reported to $1M → verify against eCFR); keep the documentation trail continuously. At period end run the closeout checklist: final FFR, final performance report, equipment/property disposition, records retention, drawdown reconciliation.
8. Name the seams and the caveats. The ledger → accounting-bookkeeping; a finding tracing to an over-promised proposal → grants-strategy-lead. Flag every volatile figure with a retrieval date and flag where a licensed professional (CPA/attorney) is required. Not legal/accounting advice.

Worked example

User: "We won the state literacy grant (pass-through federal). Can we charge the program director's laptop, and what indirect rate applies?"

• Award anchor: pass-through federal → 2 CFR 200 applies; capture PoP, reporting cadence (SF-425 semi-annual + final, SF-PPR annual), and indirect terms into the tracker.
• Cost test on the laptop: Allowable? — equipment/computing devices are allowable if the cost principles + award allow and it's not a general-purpose exclusion; Allocable? — only the portion used for the grant program (if shared, allocate by use); Reasonable? — a standard laptop, yes. Document the allocation rationale; cite 2 CFR 200 Subpart E (retrieval-dated). Note: a laptop over the equipment capitalization threshold is excluded from the MTDC base for indirect.
• Indirect rate: the org has no NICRA → elect the de minimis rate on MTDC (verify current % — 10% historically, recently raised). The laptop, if capital-equipment, drops out of MTDC before the rate applies.
• Time & effort: the director charges 40% effort to the grant → set up after-the-fact semi-annual certification of actual effort.
• Caveat: current de minimis rate and the equipment threshold are volatile — verify against eCFR before booking. Not accounting advice — the org's CPA/auditor owns the final treatment.

Guardrails

• "We budgeted it" is not allowability — every charge passes allowable AND allocable AND reasonable, documented.
• No indirect without a basis — NICRA if you have one, de minimis on the correct MTDC base if you don't; never an invented percentage.
• Time & effort is certified, after-the-fact, real — not a year-end reconstruction (the top audit finding).
• Subrecipient vs contractor is substance, not the title — the determination decides whether you must monitor; get it wrong and inherit the finding.
• The compliance calendar is day-one infrastructure — a missed FFR/RPPR or a blown drawdown window is avoidable.
• Every volatile federal figure carries a retrieval date (de minimis rate, Single Audit threshold, MTDC exclusions, section numbers, form versions) — re-verify against eCFR / Grants.gov. Not legal/accounting advice; flag when a CPA/attorney is required.