Seminar for EPA Grant Awardees and Sub-Grantees - 27th June, 2024
EPA pass-through entities, responsible for managing subawards with subrecipients, recently emphasized their key oversight responsibilities in a webinar aimed at EPA grant applicants and recipients using EPA funding for subawards.
The webinar, details of which are archived for reference purposes, focused on the oversight responsibilities of EPA pass-through entities, including selecting subrecipients, monitoring their programmatic and financial activities, ensuring compliance with federal regulations, and providing necessary administrative support to meet awarding agency requirements.
Federal regulations, such as the Uniform Guidance (2 CFR Part 200), govern these responsibilities. Pass-through entities are required to conduct risk analysis, compliance reviews, and ongoing oversight throughout the subaward period. Specific EPA or federal agency terms may further specify audit requirements and policies on management decisions regarding subrecipient audits.
In the webinar, pass-through entities were encouraged to share training information with their subrecipients. Helpful links related to the webinar, including a FAQ document (196.35 KB) and the presentation itself (912.49 KB), were made available as PDFs. Additionally, a schedule for future webinars was provided, and a recorded version of the webinar was not mentioned.
According to the webinar, pass-through entities must:
- Select subrecipients based on technical ability and capacity to perform the scope of work, as per HHS and University of Florida policies.
- Monitor subrecipients' programmatic progress and financial management continuously to ensure compliance with federal award terms, including audit compliance (2 CFR 200.331 and related sections).
- Provide administrative support to ensure subrecipients meet federal requirements and document subaward decisions, such as type of subaward and justification (HHS Grants Policy).
- Issue management decisions on subrecipient audit findings within required timeframes, generally six months after receipt (HHS Grants Policy Statement).
- Comply with audit requirements and ensure subrecipients also comply, consistent with federal requirements and agency-specific conditions (e.g., DOI Grants Terms and Conditions).
Regarding EPA-specific requirements, although not detailed explicitly in the search results, EPA typically follows 2 CFR Part 200 Uniform Guidance principles for pass-through entities, requiring the same oversight related to subrecipient monitoring, audit follow-up, and documentation of subaward management decisions.
Subscribing to the EPA Grants Update Listserv provides updates on future webinars and other relevant information. This ensures accountability and effective use of federal resources in subrecipient activities, maintaining the integrity of EPA grants and subawards.
- In light of the webinar's guidelines, pass-through entities should consider incorporating education-and-self-development opportunities for their subrecipients, focusing on enhancing financial acumen in business to effectively manage grant-funded projects.
- To comply with EPA's expectations and ensure adequate financial management, pass-through entities may find it beneficial to align business practices with financial best practices outlined in educational resources during the subaward period.
