WELCOME
STATE DIRECTORS &
YOUR STAFF MEMBERS
Breakfast
Data Recognition Corporation
Michael Johnson
Dr. Johan Uvin,
OCTAE Assistant Secretary
Agenda Overview
Design Team:
 NAEPDC: Sheryl Hart (AZ) & Sandy Crist (MS) PD
Co-Chairs plus Susan Fish (OR), Jennifer Foster
(IL), Marcia Hess (WY)
 DAEL: Cheryl Keenan, Chris Coro, Heidi SilverPacuilla , Karla Ver Bryck Block
 NOVA: Michelle Murray
Agenda Overview
NTI Design
 Five sessions, one on each of five priorities from the
August meeting
 Present options for operationalizing from which you
can chose
 Provide time to discuss the pros and cons with your
colleagues
 Provide time to plan for implementation.
Session # 1:
Compliant WIOA Competitions
Sheryl Hart (AZ) and Sandy Crist (MS)
 NTI Design Team: Susan Fish (OR), Jennifer Foster (IL),
Marcia Hess (WY)
 Checklist Background



NAEPDC solicited timelines and checklists from our members
OCTAE provided Monitoring Instrument Module 3 Funding Local
Grants
Blended those into one document, sent it out to everyone, got feedback
and produced this next iteration
Session # 1:
Compliant WIOA Competitions
Session # 1:
Compliant WIOA Competitions
The Checklist
I. Planning
I.
II.
III.
Designing your competition process
Developing your funding formula
Designing how to prepare local WIB review
II. Policy Development
III. RFP Materials
IV. Proposal Review Process
V.
Setting Up New Programs
Session # 1:
Compliant WIOA Competitions
Pre-NTI Homework
 In your email last week asking you to
1. Note additions or corrections
2. Rate each component as “comfortable” or
“uncomfortable”
3. Identify the components for which you wish
samples
Workgroup
 Review the Checklist
and Karla’s document
 Share ideas about
“comfortable” and
“uncomfortable” items
 Identify samples you
would like
 Reflect and plan your
RFP
Risk and Subaward Competitions
under the Uniform Guidance
SESSION #1
KARLA VER BRYCK BLOCK
DAEL ● OCTAE
U.S. DEPARTMENT OF EDUCATION
Purpose and Use of this Presentation
The Department of Education is providing this presentation
to help its grantees understand the contents of the Uniform
Guidance and should be viewed after or alongside of the
regulations. It is not a substitute for reading the regulations.
To get the most out of this presentation, view this as a notes
page. The notes section of each slide provides information to
supplement the points on the slide. To change to notes page:
Go to View and click on Notes Page.
Learning Outcomes
 Understand Uniform Guidance requirements on
AEFLA competitions
 Understand concepts of risk and risk-based
monitoring
 Understand the risk requirements in 2 CFR Part
200
 Be able to find the relevant regulations in 2 CFR
Part 200
 Apply this knowledge in your job
Uniform Guidance
TITLE 2 OF THE CODE OF
FEDERAL REGULATIONS,
PART 200 (2 CFR PART 200)
ACCEPTED BY THE
DEPARTMENT OF EDUCATION
IN 2 CFR PART 3474
When did 2 CFR Part 200 start?
Uniform Guidance (2 CFR Part 200) applies to:
 New and Continuation grants awarded on or after
December 26, 2014
Former regulations (EDGAR Part 74 or 80 and OMB
circulars) apply to:
 Grants awarded prior to December 26, 2014
Definitions: Pass-through entities
A non-Federal entity that provides a subaward to a
subrecipient to carry out part of a Federal program
(§200.74).
At ED:
 State-Administered Formula Grants: SEAs, other grantees
which make subawards
Definitions: Subrecipient and Contractor
A pass-through entity must determine the
relationship and the applicable requirements:
 Subrecipient means a non-Federal entity that
receives a subaward from a pass-through entity to
carry out part of a Federal program (§200.93).
 Contractor means an entity that receives a contract as
defined in 200.22 Contract (§200.23).
 §200.330 explains the roles of subrecipients and
contractors
Understanding Risk
What is Risk? (GAO – The Green Book)
Risk is the possibility that an event
will occur and adversely affect the
achievement of objectives.
What is Risk Management? (GAO)
Risk management can be described as the
continuous process of assessing risks,
reducing the potential that an adverse event
will occur, and putting steps in place to deal
with any event that does occur.
Risk Management
Risk Assessment
Risk-Based
Monitoring
Risk Mitigation
Risk and Monitoring
KEY CONCEPTS AND
CHANGES IN THE UNIFORM
GUIDANCE
Indicates a new requirement or change to existing
requirement for pass-through entities.
Parallels: ED and Pass-through entities
Whether an ED program office or pass-through entity,
the following concepts are the same. The practices and
tools, however, may differ.
 Risk Assessment,
 Risk Mitigation, and
 Risk-based Monitoring.
Overview (2 CFR 200.331)
Grantees, as pass-through entities, must:
 Assess risk of subrecipients. (§200.331(b))
 Monitor to ensure the subaward is used appropriately
and in compliance with the award and all associated
regulations. The monitoring plan should be based on
the results of the risk assessment. (§200.331(d))
The risk assessment and monitoring should
address both financial and programmatic
considerations.
Where are the Requirements?
Topic
Pass-through
entities
Award
Notification
§200.331(a)
Risk Assessment
§200.331(b)
Specific
Conditions
§200.207*
High-Risk
Designation
§3474.10
Monitoring
§200.331(d)-(e)
Subpart F*
Non-Compliance
§200.338*
*Section 200.331
references these
sections for
requirements.
Pass-Through Risk Review (§200.331(b))
Items that may be part of the pass-through entity’s
review:
 Prior experience with same or similar subawards
 Results of previous audits
 Whether new or substantially changed personnel or
systems
 Extent and results of Federal awarding agency
monitoring
Risk Rubric
Risk Rubric highlights




Risk indicators
Risk categories
Scoring mechanism
Risk designation levels
Specific Conditions (§200.207)
If deemed appropriate based on the risk
assessment, specific conditions (e.g., increased
reporting, reimbursement plan) may be placed
on:
 A subaward from a pass-through entity
(§200.331(c) refers to (§200.207))
In addition, a high-risk designation can be added
to a subaward, as per §3474.10.
Other Pass-through Requirements
The pass-through entity must provide specific
information in the subaward (§200.331 (a)),
including but not limited to:
 Federal award identification, e.g., DUNS number
 Indirect cost rate (restricted rate)
 Requirements imposed by the pass-through entity
 Requirement to provide access to records for audit
Pass-Through Monitoring Procedures
 When monitoring subrecipients, the pass-
through entity must (§ 200.331(d)):
Review reports required by the pass-through entity
 Ensure subrecipient takes appropriate action on
deficiencies identified through audits, on-site reviews,
and other means
 Issue a management decision for single-audit findings
pertaining to Federal award

 Verify audits of subawards (§ 200.331(f))
 Threshold for required audits increased to $750,000
Pass-Through Entity Monitoring Tools
 The following tools may be useful, depending
upon the risk assessment (§ 200.331(e))



Providing subrecipient training and technical assistance
Performing on-site reviews
Arranging for agreed-upon-procedures engagements
under § 200.425, Audit services [in Cost Principles]
The pass-through entity determines which tools
to use based upon its assessment of risk
Risk-Based Monitoring Plan
Monitoring Plan highlights
 Assessment methodology
 Last Fiscal Year (FY) assessment & monitoring
activities
 Current fiscal year assessment & monitoring
strategies
 Resource constraints
Audit Requirements
Single Audit (2 CFR Part 200 Subpart F)
Alternatives to Single Audits
 Program specific audit
 Agreed-Upon-Procedures
Additional Audits, as requested by Congress or the
Federal Government
 GAO Audits
 OIG General Audits
Continuous Improvement Standard
Evaluate annually the risk management
process to identify its strengths and
weaknesses and refine ability to reduce risk
throughout the grant process
Compliance: Grantees
Responsibility for subawards:
 Strong Internal Controls for managing subawards
 Communication with ED Staff and with
subrecipients
 Documentation of all activities
 Monitoring subawards
 Verifying subgrantees are audited, if required
Uniform Guidance Resources
 Technical Assistance for ED grantees may be found
at http://www2.ed.gov/policy/fund/guid/uniformguidance/index.html
Session # 1:
Compliant WIOA Competitions
(Karla)
Click
Session # 1:
Compliant WIOA Competitions