Navigating Federal Grant Compliance, Part 3

Federal grants are managed and administered under Uniform Guidance within 12 different compliance requirements. In the last two blog installments we looked at six of those requirements. Let’s continue on the journey of understanding the compliance requirements by looking closer at equipment and real property management (F), procurement and suspension and debarment (I), and special tests and provisions (N).

Equipment and real property management

Grantees that purchase equipment and real property with federal funds are required to use these purchases for the intended purpose of the program and maintain adequate records. Records should contain:

• Descriptions
• Serial numbers
• Which grant it is for
• When it was purchased
• Cost
• Location
• Disposal date (once it is sold)

Taking a physical inventory of the equipment and real property is required.

Once equipment and real property is purchased with federal funds, organizations are required to keep the property in good working condition. Organizations also need to have systems in place to prevent potential theft, loss, or damage to the equipment and real property.

Procurement and suspension and debarment

This compliance requirement has two different components. Procurement is the process of obtaining goods and services that includes selecting vendors based on five different methods to secure the goods and services at fair prices. The procurement methods can be found within the Uniform Guidance 2 C.F.R. Part 200.320. Organizations should have a procurement policy that describes the guidelines and practices used.

Contracts and sub-awards using federal funds cannot involve parties that are either temporarily suspended or permanently debarred due to misconduct or noncompliance. Prior to entering into a transaction, the excluded parties list should be reviewed at SAM.gov.

Special tests and provisions

Each federal program may have non-standard requirements that must be followed to be in compliance with program regulations. The special tests and provisions are unique to each program, so it is important to understand the program requirements.

Obtaining grant agreements and manuals is the first step to determining if your federal programs have these requirements. The compliance supplement often includes these provisions for specific assistance listing numbers.

More from this blog series

• What Is a SEFA?
• Navigating Federal Grant Compliance
• Navigating Federal Grant Compliance, Part 2

How we can help

Set aside time to understand the compliance requirements applicable to the grants included in your organization’s Schedule of Expenditures of Federal Awards. If you would like further assistance or possible training opportunities for your organization, CLA has team members experienced in grant compliance services.