Rhode Island Office of Management & Budget 1 SUB-RECIPIENT AND CONTRACTOR D E T E R M I N AT I O N S APRIL 28, 2016 Rhode Island Office of Management & Budget 02/21/2020 Agenda 2 When is a Entity a Sub-Recipient and Not a Contractor? Laurie Petrone, Office of Management and Budget Schedule of Expenditures of Federal Awards Jenny Findlay, Office of Accounts and Controls Purchasing Instruments Changes Required for SFY 2017 Nancy McIntyre and Cheryl McGurn, Division of Purchases Rhode Island Office of Management & Budget
02/21/2020 Uniform Grant Guidance: A Primer 3 Applies to: Non-federal Entities Replaces existing circulars: A-87 A-102 2 CFR 200 A-133 Effective Date: December 2014 26
States Local Government Tribal Nations Non-Profits Institutions of Higher Education (IHE) Guidance for Federal and Non-Federal Entities that applies to: Grants Co-op Agreemen ts
Contracts Cost Principles only Federal contracts follow the FAR, plus UG for cost principles only Rhode Island Office of Management & Budget 02/21/2020 Federal Program Governance 4 Rhode Island Office of Management & Budget 02/21/2020 Definitions 2 CFR 200 5 Sub-recipient means a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a federal
program; but does not include an individual that is a beneficiary of such program. A sub-recipient may also be a recipient of other Federal awards directly from a Federal awarding agency. 2 CFR 200.93 Sub-award means an award provided by a pass-through entity to a sub-recipient for the sub-recipient to carry out part of a Federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal program. A sub-award may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. 2 CFR 200.92 Rhode Island Office of Management & Budget 02/21/2020 Definitions 2 CFR 200 6 Contractor means an entity that receives a contract as defined in 200.22 Contract. (Note: Replaces term vendor used in previous guidance).
2 CFR 200.23 Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award. The term as used in this part does not include a legal instrument, even if the nonFederal entity considers it a contract, when the substance of the transaction meets the definition of a Federal award or subaward. 2 CFR 200.22 Rhode Island Office of Management & Budget 02/21/2020 Definitions 2 CFR 200 7 Non-Federal entity means a state, local government, Indian tribe, institution of higher education (IHE), or nonprofit organization that carries out a Federal award as a recipient or sub-recipient. 2 CFR 200.69 A non-federal entity can be
Recipient Sub-recipient Contractor Pass-through entity means a non-Federal entity that provides a sub-award to a sub-recipient to carry out part of a Federal program. 2 CFR 200.74 Rhode Island Office of Management & Budget 02/21/2020 Sub-Recipient / Contractor Determinations 8 The pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of federal program funds casts the party receiving the funds in the role of a sub-recipient or a contractor.
The Federal awarding agency may supply and require recipients to comply with additional guidance to support these determinations provided such guidance does not conflict with this section. 2 CFR 200.330 Rhode Island Office of Management & Budget 02/21/2020 Sub-Recipient Characteristics 9 Sub-Recipient: A sub-award is for the purpose of carrying out a portion of a federal award and creates a federal assistance relationship with the sub-recipient. Determines who is eligible to receive what Federal assistance; Has its performance measured in relation to whether objectives of a Federal program were met; Has responsibility for programmatic decision making; Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and
In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the passthrough entity. 2 CFR 200.330(a)(1-5) Rhode Island Office of Management & Budget 02/21/2020 Contractor Characteristics 10 Contractor. A contract is for the purpose of obtaining goods and services for the non-federal entity's own use and creates a procurement relationship with the contractor. Provides the goods and services within normal business operations; Provides similar goods or services to many different purchasers; Normally operates in a competitive environment; Provides goods or services that are ancillary to the operation of the Federal program; and Is not subject to compliance requirements
2 CFR 200.330(b)(1-5) Rhode Island Office of Management & Budget 02/21/2020 Judgement is Involved 11 In determining whether an agreement between a pass- through entity and another non-Federal entity casts the latter as a sub-recipient or a contractor, the substance of the relationship is more important than the form of the agreement. All of the characteristics listed above may not be present in all cases, and the pass-through entity must use judgment in classifying each agreement as a sub-award or a procurement contract. Look at the nature of the relationship. It does not matter what the agreement is called. 2 CFR 200.330(c) 85-90 percent of cases are black and white.
The rest are gray,&and this is where judgement comes in!02/21/2020 Rhode Island Office of Management Budget Sub-Recipient /Contractor Determination Tool 12 Rhode Island Office of Management & Budget 02/21/2020 Sub-Recipient /Contractor Determination Tool 13 Rhode Island Office of Management & Budget
02/21/2020 Sub-Recipient /Contractor Determination Tool 14 Questions That May Reveal Characteristics Indicative of a SubRecipient: Will the entity have the authority to make decisions about the delivery of the program, in accordance with federal regulations? Will the entity have the authority to determine who is eligible for the program? Will the entity use the funds to carry out a public project and/or provide a public service?
Did the state agency make an announcement that funding was available or that it was seeking applications for funding, even if funds were to be awarded on a competitive basis? Rhode Island Office of Management & Budget 02/21/2020 Sub-Recipient /Contractor Determination Tool 15 Questions That May Reveal Characteristics Indicative of a SubRecipient: Will the entity be required, as a condition of receiving
federal funds, to contribute match or in-kind funds to the project? Will the entity be reimbursed for actual costs incurred for allowable activities outlined in the agreement and generally not earn a profit as a result of the agreement? Will the entity be required to follow federal requirements specified in the federal award? Will the entity have its performance measured against the goals and objectives of the federal program or program as outlined in the federal award letter? Rhode Island Office of Management & Budget 02/21/2020 Sub-Recipient /Contractor Determination Tool 16 Questions That May Reveal Characteristics Indicative of a Contractor:
Will the entity provide goods or services that are ancillary to the operation of the federal program? Does the entity provide similar goods and services to many different purchasers within the normal business operations? Does the entity operate in a competitive environment, i.e., compete with other organizations to provide a similar good or service? Was the entity selected based on price alone subsequent to a request for quotes? Rhode Island Office of Management & Budget 02/21/2020 Sub-Recipient /Contractor Determination Tool
17 Questions That May Reveal Characteristics Indicative of a Contractor: Will the entity be paid a set fee or fixed price above its costs (profit) for the goods and services outlined in the agreement? Will the entity have its performance measured against whether it meets specific contract deliverables rather than the program outcomes? Will the entity assume all financial risk if they fail to deliver the agreed upon good and services? Rhode Island Office of Management & Budget 02/21/2020
Test Yourself . . . Sub-Award or Contract? #1 18 Recruit, hire train, support, and evaluate consumers who must be current or recent consumers of Department of Health programs Gather systematic feedback as to how Maternal & Child Health programs are working at both the community and state level. Help families to identify and understand the eligibility criteria for various benefit/entitlement programs Assist families in accessing insurance or other financial assistance for health care Assist in data collection, surveys, assessment and reporting as required. Report quarterly on program services provided under the auspices of this task
Recommend changes and/or modifications to programs, policies and procedures, and the service delivery system based on feedback Adhere to all the OMB Circular A-122, Cost Principles for Nonprofit Organizations, and especially Attachment B, Section 25 Lobbying Rhode Island Office of Management & Budget 02/21/2020 Test Yourself . . .Sub-Award or Contract? #2 19 The overall goal of this agreement is to provide epidemiological and analytical support to programs for short and long-term projects. The entity will focus on activities related to epidemiology, program
evaluation, community needs assessment, and other public health related data analyses via consultant services provided to department The number of projects and activities to be performed will be dependent on the needs of programs and available funding. The entity will use a Task Order method to supply the data, information, and analytical expertise required. Analyze the RI Behavioral Risk Factor Surveillance System (BRFSS) weighted data set to determine the relationship between social determinants of health and survey variables associated with healthrelated Quality of Life. In addition to the analyses, deliverables will include the production of two infographic fact sheets. Data collection and analysis have defined schedules for the production of reports dictated by existing requirements or mandated by legislative or funding sources. Rhode Island Office of Management & Budget 02/21/2020 Test Yourself . . .Sub-Award or Contract? #3 20 Platform to Employment (P2E) will serve 175 individuals who are
long-term unemployed. The program will: Provide a five week job readiness component (boot camp); Provide financial coaching; Support the participant with behavioral health services; Seek to place participants in an eight week paid internship in a company that can provide an occupation that closely matches the participant's skill set; and, Provide post-graduation services in partnership with the Rhode Island Jobs Club who will offer on-going job club services. P2E and DLT will develop a letter to be sent to JD NEG eligible participants in the state. This letter will be on DLT letterhead and DLT will mail the letter. The letter will provide specific steps for unemployed individuals to complete P2Es on-line application. Project's Measurable Outputs and Outcomes
Input-Outreach to target population -long-term unemployed: 400 Input-Enrollments: 175 participants (Seven cohorts of 20-28) Output-Participate psychological assessment: 170 Rhode Island Office of Management & Budget 02/21/2020 If Sub-Award, Then Agency Must 21 Identify as Sub-Award Include specific award elements in agreement. OMB Form 15-01 (2 CFR 200.331) Terms and Conditions Ensure that the federal award is used in accordance with federal statute, regulations, and federal award terms and conditions Indirect Cost Rate Federally approved, state-negotiated, or de minimis rate
Sub-recipient risk assessment Sub-recipient monitoring Financial Programmatic performance Single Audit Management decision, if appropriate FFATA reporting Rhode Island Office of Management & Budget 02/21/2020 Resources 22 Presentation materials and reporting tools will be available for download early next week at: www.omb.ri.gov/grants For more information, contact: Laurie Petrone 574-8423 [email protected] Rhode Island Office of Management & Budget
02/21/2020 Agenda 23 When is a Entity a Sub-Recipient and Not a Contractor? Laurie Petrone, Office of Management and Budget Schedule of Expenditures of Federal Awards Jenny Findlay, Office of Accounts and Controls Purchasing Instruments Changes Required for SFY 2017 Nancy McIntyre and Cheryl McGurn, Division of Purchases Rhode Island Office of Management & Budget 02/21/2020 Sub-award General Ledger Reporting 24 Effective July 1, 2016, agencies will be required to use a new natural specifically for sub-awards. This will ensure correct reporting of federal awards passed through to sub-recipients,
which is required under federal Uniform Administrative Requirements, Cost Principles, and Audit Requirements. The federal (source 02) amounts identified under this new natural will be reported on the Statement of Expenditures of Federal Awards (SEFA), part of the States Single Audit report. Rhode Island Office of Management & Budget 02/21/2020 Sub-award General Ledger Reporting 25 Natural 654130, Payments of Sub-Awards: use beginning on July 1, 2016. This natural is exclusively for expenditures which are payments passed through to sub-recipients as subawards. Use regardless of source of funds general revenue, federal, restricted, etc. Natural 654120, Other Grants will be deactivated after
SFY16. Any naturals currently in use for payments of sub-awards should be coded as 654130 beginning on 7/1/2016. Rhode Island Office of Management & Budget 02/21/2020 State Agency to State Agency Sub-Awards 34 26 Federal Agency GAN Recipient State Agency Pass Through Entity MOU First Tier Sub-Award State Agency Internal / Agreements First Tier Sub-Award
Personnel Expenses Second Tier Sub-Award Entity Outside of State 654130 Rhode Off ice of Management & Budget RhodeIsland Island Office of Management & Budget First Tier Sub-Award Contracts Goods and Services 02/21/2020 4/ 28/ 2016 Exception: Transfers to Component
Units 27 Agencies making payments of sub-awards to State Component Units will continue to use natural series 692110 through 692295, Transfers to CU-XXX. Transfers to Component Units must be disclosed in the notes to the Comprehensive Annual Financial Report (CAFR) separately, under Governmental Accounting Standards Board (GASB) standards. For the purposes of sub-award reporting, these transfers will be identified by alternate means by the Office of Accounts and Control in order to include in the SEFA sub-award report. Rhode Island Office of Management & Budget 02/21/2020 Transfers to Component Units 28
Component Unit University of Rhode Island Rhode Island College Community College of Rhode Island Central Falls School District The Metropolitan Regional Career and Technical Center Rhode Island Commerce Corporation Rhode Island Convention Center Authority Rhode Island Public Transit Authority Rhode Island Housing and Mortgage Finance Corporation Quonset Development Corporation Rhode Island Resource Recovery Corporation Rhode Island Turnpike and Bridge Authority Rhode Island Airport Corporation Natural 692110 692120 692130 692140
I-195 Redevelopment District Commission 692295 Rhode Island Office of Management & Budget 692145 692150 692160 692180 692220 692270 692280 692285 692290 Natural Description Transfer To CU-URI Transfer To CU-RIC Transfer To CU-CCRI Transfer To CU-CFSD Transfer to CU-Met Center
Transfer To CU-RICC Transfer To CU:RICCA Transfer To CU-RIPTA Transfer To CURIHMFC Transfer To CU-QDC Transfer To CU-RIRRC Transfer To CU-RITBA Transfer To CU-RIAC Transfer To CU-I195RDC 02/21/2020 Transfers to Related Organizations 29 Related Organizations are quasi-public agencies which do not meet the GASB criteria for inclusion in the CAFR as component units. Agencies making transfers (payments) of sub-awards to State Related Organizations will use natural 654130 as of 7/1/2016. Rhode Island Infrastructure Bank (formerly Rhode Island
Clean Water Finance Agency) Rhode Island Health and Education Building Corporation Narragansett Bay Commission Rhode Island Student Loan Authority Rhode Island Office of Management & Budget 02/21/2020 SFY16 Year-End Accruals 30 Agencies will use the sub-award expenditure naturals currently in use during SFY 2016, for accounts payable accruals at 6/30/2016. Automatic reversals of accounts payable accruals in SFY 2017 will be reclassified to the natural 654130, so that proper SEFA reporting can occur. Accounts and Controls will assist in identifying and reclassifying those accrual reversals. Rhode Island Office of Management & Budget
02/21/2020 Batch Payments Changes 31 Agencies that use batch payment systems must change their data base for payments of sub-awards to natural 654130, effective 7/1/2016. Rhode Island Office of Management & Budget 02/21/2020 Office of Accounts and Control 32 For more information regarding the general ledger reporting of sub-awards in SFY17 and beyond, please contact: Jenny Findlay 222-5771 [email protected]
Rhode Island Office of Management & Budget 02/21/2020 Agenda 33 When is a Entity a Sub-Recipient and Not a Contractor? Laurie Petrone, Office of Management and Budget Schedule of Expenditures of Federal Awards Jenny Findlay, Office of Accounts and Controls Purchasing Instruments Changes Required for SFY 2017 Nancy McIntyre and Cheryl McGurn, Division of Purchases Rhode Island Office of Management & Budget 02/21/2020 Purchasing Instruments 34 Two types of Purchase Orders:
Purchase Agreements Standard Purchase Order Sole Source and Delegated/Grants are either Purchase Agreement or Standard Purchase Order To reiterate, the current RIFANS natural account 654120 will be eliminated effective 6/30/16 New RIFANS natural account 654130 must be used 7/1/16 and is specific to sub-awards to sub-recipients Use 654130 for payments for sub-awards to sub-recipients Fiscal Year SFY 17 releases Rhode Island Office of Management & Budget 02/21/2020 Required Agency Action Items 35 Agencies are responsible to examine existing purchase agreements to determine sub-recipients based upon subrecipient characteristics. A report of these releases against purchase agreements is forthcoming and will be distributed in the near future.
A RIFANS report listing has been generated for SFY 16 agency standard purchase orders currently under natural account 654120 and will be provided to agencies today. Agencies are responsible to review this data to: Determine sub-recipient purchase orders based upon sub-recipient characteristics Refer to 3/18/16 Fiscal Year Transition Timetables and Deadlines Memo for action item timelines Perform releases and purchase orders by required timeline Perform any necessary action by required timeline for purchase orders: that are finalized and in need of agency close out; or determined Non-sub-recipients and in need of agency change to other Rhode Island Office of Management & Budget 02/21/2020 natural account and perform change order RIFANS SFY17 Action Plan 36 If agency determines agreement is a sub-recipient based upon characteristics:
At this time, RIFANS rollover is planned to be performed by DOA Purchases for the Purchase Orders changing to the 654130 account. Standard Purchase Orders scheduled to roll over will not be available until 8/1/16 If the rollover is unsuccessful the Agency is responsible to perform necessary resolve Purchases will issue instruction based upon the RIFANs rollover results For Standard Purchase Orders improperly classified at this time as natural account # 654120 and subject to roll over Agencies must not allow roll over to the new account # 654130. The agency must process a change order to the appropriate natural account prior to 6/30/16. Helpful tool for requisitioning staff - New Purchases RIFANS Requisitioner 101 Training Manual will soon be stored in the Agency Info Center Training Folder Rhode Island Office of Management & Budget 02/21/2020 New Request For Proposal (RFPs) 37
Sub-Recipient/Sub-Award Agency Action Agencies must use the new account #654130 on the Requisition Rhode Island Office of Management & Budget 02/21/2020 Office of Purchases 38 For questions related to purchasing and roll-overs, please contact: Donna Brennan 574-8129 [email protected] Diane Tambashi 574-8107 [email protected] Rhode Island Office of Management & Budget 02/21/2020
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