Tales from the Classroom

Over the last few months, I have traveled across the country teaching the full range of Management Concepts’ Grants curriculum to Federal employees and grant recipients. I view my time in the classroom as a mutually beneficial experience: Participants learn our grants curriculum and I learn from participants about their specific grants management challenges and best practices.

For this blog, I want to share some of the common questions and concerns I hear regarding grants management from Federal grants personnel and recipients.

Contracts vs. Subawards

2 CFR 200.330 provides guidance to grant recipients in determining which instrument should be used: A contract or a subaward. While the language in the provision provides a useful checklist, many participants in my classes have provided some tremendous examples of complex situations in which a clear answer is not readily available. I thoroughly enjoy when participants ask these questions in the classroom. Generally, I will walk the class through the language in 2 CFR 200.330 and encourage discussion for participants to reach their own conclusion. I find it fascinating when some members of the class conclude a contract should be used, and others feel a subaward is the appropriate instrument.

There are definitely some gray areas in contract and subaward determination. My best recommendation to participants, if they find themselves in this situation, is to document their instrument selection decision process by using the language in 2 CFR 200.330 and provide a detailed explanation.

Awards to International Organizations and Institutions of Higher Learning

If you have taken a course with me, you have heard me repeatedly say the phrase “This is how it generally works…. unless you are from a college, university, or international organization.” Research awards and international awards are, sometimes, very different creatures, and it is interesting to hear participants share their experiences in managing their specific awards.

For example, research awards have a higher micro-purchase threshold, expanded authorities that waive some prior approval requirements, and use the additive method for program income. After reviewing the exceptions to research awards, multiple participants have commented that they need to find a grants management position in a university. When employees from the University of Hawaii were recently in one of my classes, quite a few of us were envisioning working in the Aloha State!

Agency Implementation and Interpretation

Perhaps the most fun I have in the classroom is hearing how different agencies have implemented 2 CFR 200 and the differing interpretations of grant compliance requirements. For example, when teaching our Cost Principles course, it has been interesting to see which agencies apply the cost principles under the Federal Acquisition Regulation (FAR) to for-profit entities, and which apply the Subpart E of 2 CFR 200. This only reemphasizes the importance for grant recipients to carefully review the terms and conditions of their awards from differing agencies.

Dedication to the Public Good

The most rewarding part of being in the classroom is seeing highly dedicated individuals who have the desire to learn how to better manage their grants to provide quality services to their communities. Honestly, it is inspiring to meet so many people determined to do good.

For those of you that have been in my classes, I thank you for sharing your stories, for teaching me about your practices, and humoring me when I “dork-out” about audits and performance measures. If you haven’t been in my class yet, I can’t wait to share my love of the Federal Audit Clearinghouse with you!