The document authored by Pamela Webb for the Council on Governmental Relations (COGR) in October 2017 outlines several unresolved challenges associated with federal subawards and subrecipient monitoring. Key issues addressed include the establishment and application of de minimis Facilities & Administrative (F&A) rates, particularly for for-profit entities and those with expired rates. The document highlights complexities around risk assessment, such as the proper timing for conducting assessments, reliance on the Federal Audit Clearinghouse (FAC), and the potential for the FDP Expanded Clearinghouse to serve as an alternative data source. A lack of standardization and increased administrative burden are noted concerns for fixed price subawards, especially in cases exceeding the simplified acquisition threshold, those involving multiple subawards to the same recipient, and the unique management challenges in clinical trial settings.
Additional concerns focus on foreign subawards, including ambiguity over federal registration requirements and the need for appropriate risk assessment standards for foreign entities. The acceptance of negotiated F&A rates by both federal agencies and pass-through entities is also identified as an outstanding issue. The document concludes with a call for input to finalize and prioritize these open issues, determine which concerns COGR and potentially FDP can influence, and establish recommendations for improvements.
