Grant Financial Requirements 

Presented by:

Michael Williams/OCFO 
Financial Management Systems
Financial Management Systems

In summary, a Financial Management System 

must be able to record and report on the:

– Receipt;

– Obligation; and 

– Expenditures of grant funds. 
MATCH REQUIREMENTS
CASH versus 

IN-KIND 
How to Calculate Match
Conference Approval, 

Planning, and Reporting
Conference Definition

• A conference defined broadly can be a 

meeting, retreat, seminar, symposium, or 

other training activities.

• Some typical characteristics of a conference 

are:

– Designated participants and/or registration;

– A published substantive agenda; and

– Scheduled speakers or discussion panel 
Conference Approval

• OJP developed a checklist to alleviate some of 

the uncertainty regarding whether an event 

requires prior approval.

• If all the answers to the ten questions are 

"No," the event does not require prior 

approval.
Conference Checklist

1. Is the cost of the event greater than $20,000?

2. Are there meeting room costs?

3. Are audio-visual costs greater than $25 per 

attendee or more than $1,000 in total?

4. Are there any food and beverage costs?

5. Did the request for the meeting come from 

multiple jurisdictions or agencies?
Conference Checklist

6. Do the participants represent multiple agencies 

that are not co-located or joined by an agreement 

(e.g., task force with MOU)?

7. Are there trinkets being purchased?

8. Is there a formal published agenda?

9. Are formal discussions or presentation panels 

planned?

10.Are there logistical planning costs beyond 

incidental internal administrative costs necessary 

to arrange travel and lodging for a small number 

of individuals?
Reporting Requirements
Reporting Requirements

REPORT SYSTEM

FFR/SF-425

Federal Financial Report (Formerly 

SF-269)

Grants Management System (GMS)

Progress Reports

Program/Project Activity Reports

Grants Management System (GMS)

Performance Measures Performance Measurement Tool (PMT)

Grants Management System (GMS)

Other Reports

Conference Cost Reporting 

OJPConferenceCostReporting@ojp.us 

doj.gov 
Federal Financial Report (SF-425)

 Quarterly Federal Financial Reports are submitted 

through the Grants Management System (GMS) at 

https://grants.ojp.usdoj.gov.

 The SF-425 quarterly report must be submitted no 

later than 30 days after the end of each calendar 

quarter. 
CLICK HERE
cinderella

*********

Smallville Police Department

123 Main Street

Nicetown, USA 12356

2009-XX-XX-1234

2009-XX-XX-1234

03/31/2010

.

$2000.00 $17000.00

$500000.00

$19000.00

$5000.00

$24000.00

$476000.00
$3500.00

$2000.00 $500.00 $2500.00

$1000.00

$400.00

$400.00

$0.00
10.0 01/01/2009 12/31/2009 9000.00

$900.00

$900.00

$900.00

$900.00
Chief Financial Officer

jdoe@smallvile.gov

Doe

912345678

10/25/2009

John

Mr

2 C.F.R. Part 200.500

also known as OMB A-133

Audit Requirements

State, Local Governments, & 

Non-Profit Organizations
WE WON THE 

OIG AUDIT 

SWEEPTAKES!
Audit Requirements

 2 CFR Part 200.500 applicable to Gov't, Education 

and Non-Profit

 Thresholds $750K or more expended during the FY -

Single Audit required

 Audit Report - due nine (9) months after end of FY 

 Submit online to Federal Audit Clearinghouse (FAC)

 $15,000 or more in questioned costs must be 

included in the Single Audit report
Top Ten Audit Findings (FY 2014)

1. Procedures not documented or need improvement –

Internal Controls. 

2. Procedures not documented or need improvement –

Accounting. 

3. Special conditions not met by grantee –

unsupported/unauthorized expenditures/drawdowns.

4. Accounting system inadequate or not effectively utilized to 

account for grant funds.

5. Procedures not documented or need improvement –

Payroll. 
Top Ten Audit Findings (FY 2014)

6. Quarterly Financial and Annual Program Reports 

not submitted timely. 

7. Procedures not documented or need 

improvement - Inventory. 

8. Quarterly Financial and Annual Program Reports 

not accurately prepared. 

9. Suspension and Debarment – verification not 

performed or not properly documented. 

10. Subrecipient monitoring not being conducted. 
Sub-recipient vs. 

Contractor
Definitions

• Sub-recipient – means a non-Federal entity that 

receives a sub-award from a pass-through entity 

to carry out a Federal program, but does not 

include an individual that is a beneficiary of such 

a program. 

• Contractor – means an entity that receives a legal 

instrument from a non-Federal entity to provide 

property or services needed to carry out the 

project or program under a Federal award. 
Sub-recipient Determination

• The pass-through entity must make a case-bycase determination to:

– Determine who is eligible to receive funds

– Ensure sub-award recipient adhere to the 

requirements specified in the Federal award.

– Determine if objectives were met in accordance to

Federal program 
Contractor Determination

• A contract for goods and services creates a 

procurement relationship with the contractor 

when: 

– Operates in a competitive environment 

– Not subject to compliance requirements of the 

Federal program 
Sub-recipient Monitoring 
Monitoring Responsibilities

Pass-through entity:

• Must provide reasonable assurance that sub-recipients are 

incompliance with Federal program guidelines and 

requirements.

• Inform each sub-recipient of CFDA title and number, award 

name and number, and award year.

• Advise sub-recipient of requirements imposed on them by 

Federal laws, regulations, and provisions of contracts or 

grant agreement.

• Advise of any supplemental requirements imposed by the 

pass-through entity.
Monitoring Responsibilities

Pass-through entity: (cont’)

• Monitor the activities of sub-recipients to ensure funds 

are used for authorized purposes and performance goals 

are achieved. 

• Ensure that sub-recipients that expend $750,000 or more 

in their fiscal year follow the audit requirements in OMB 

Uniform Requirements (2 CFR Part 200.500). 

• Issue a management decision on audit findings within 6 

months after receipt of the sub-recipient’s audit report. 

• Ensure that the sub-recipient takes appropriate and timely 

corrective action. 
Monitoring Responsibilities

Pass-through entity: (cont’)

• Require each sub-recipient to permit the pass-through 

entity and auditors to have access to the records and 

financial statements as necessary. 
What Your Sub-recipient Should 

Know

• Seek prior approval for certain costs and extensions 

to grant closing date. 

• Method in which they will be paid and any 

documentation that should accompany the claim. 

• Documenting the allowable sources of matching 

funds. 

• Prohibition of using the federal award to supplant 

existing resources.

• Maintain property records for equipment and perform 

physical inventory of equipment.

• Accounting for and using program income.
Factors to Consider When Monitoring 

Sub-recipients 

• Dollar amount of awards provided to sub-recipients. 

• Number of sub-recipient can effect how often you 

monitor them. 

• Complexity of program requirements. 

• Sub-recipient’s control environment (i.e., staffing levels, 

computer system, etc.). 

• Results of prior audits. 

• Sub-recipient with frequent requests for budget 

modifications, extensions, or exceptions to the rules. 
When Monitoring Your Sub-recipients 

• Perform an on-site visit to review financial and 

programmatic records and observe operations. 

• Reconcile the sub-recipient’s budgeted expenditures to 

actual.

• Offer sub-recipients technical assistance where 

needed. 

• Perform desk reviews to ensure allowable use of grant 

funds. 

• Have a second party within your organization 

periodically review the sub-recipient monitoring plan 

and reports. 
Document Your Efforts

• Maintain a file or record of the desk reviews that you 

perform and the results. 

• Develop a schedule of dates to perform on-site visits. 

• Document the work performed and the results of onsite visits. 

• Document corrective action taken by sub-recipient and 

follow-up work performed by you. 

• Retain a copy of the management decisions you 

issued in response to sub-recipient audit findings. 
System for Award Management 

(SAM) 

• The first-tier sub-recipient are required to register in 

the System for Award Management (SAM) 

registration, including obtaining a Dun and Bradstreet 

Data Universal Numbering System (DUNS) number. 
Penalties & Sanctions 

• Withholding of disbursements or future awards;

• Disallowance of cost;

• Suspension/Termination of award;

• Suspension/Debarment of Association;

• Civil lawsuit; or

• Criminal prosecution. 
FEDERAL FUNDING 

ACCOUNTABILITY AND 

TRANSPARENCY ACT OF 2006 

(FFATA)

Sub–recipient 

Reporting
Subaward and Executive Compensation

Requires prime recipients to report on first-tier 

subawards of $25K or more.

Requires prime recipients to report executive 

compensation for prime or subawards if:

 The organization received 80% or more of its annual 

gross revenues in Federal awards and those revenues 

are greater than $25 million; and

 The public does not have access to information about 

executive compensation through periodic reporting.
When to Report

 For Federal awards of $25K or more the 

prime recipient must report first-tier and 

executive compensation data. 

 Data must be reported in FSRS the following 

month after the obligation is made.

Example: Awards made during October will have 

until November 30th to report.
Subaward and Executive Compensation

 Prime recipients must report FFATA 

requirements in the (FFATA) Subaward

Reporting System (FSRS) 

https://www.fsrs.gov/.
Questions & Answers (Q&A)