CGA Professional Development & Ethics 3 — Questions and Answers
Question 1: A grant administrator is asked by their supervisor to approve an expenditure they believe is unallowable under 2 CFR Part 200. The appropriate ethical response is to:
- Approve it to avoid conflict with the supervisor
- Document their objection in writing and escalate to legal or compliance staff (Correct answer)
- Approve it but note the concern verbally
- Resign from the organization immediately
Correct answer: Document their objection in writing and escalate to legal or compliance staff
Grant administrators must document concerns in writing and escalate to appropriate authorities rather than silently complying with potentially improper directives.
Question 2: Which federal regulation establishes the code of conduct requirements that organizations must have in place when managing federal awards?
- 2 CFR Part 25
- 2 CFR Part 200.318 (Correct answer)
- OMB Circular A-110
- 31 CFR Part 205
Correct answer: 2 CFR Part 200.318
2 CFR Part 200.318 requires organizations to maintain written standards of conduct covering conflicts of interest in procurement under federal awards.
Question 3: A grant administrator who learns of waste, fraud, or abuse in a federal grant program has a protected right to report this information under which law?
- The Federal Acquisition Regulation
- The False Claims Act and whistleblower protection statutes (Correct answer)
- The Single Audit Act
- The Administrative Procedure Act
Correct answer: The False Claims Act and whistleblower protection statutes
The False Claims Act and related whistleblower protection statutes protect individuals who report fraud against the federal government from retaliation.
Question 4: Which of the following best describes the ethical principle of 'stewardship' in grant management?
- Maximizing administrative overhead to support organizational sustainability
- Treating grant funds as a public trust and using them solely for intended purposes (Correct answer)
- Building personal relationships with program officers to secure future funding
- Spending all grant funds before the project period ends regardless of results
Correct answer: Treating grant funds as a public trust and using them solely for intended purposes
Stewardship means managing grant resources responsibly as a public trust, ensuring funds are used only for allowable and intended purposes.
Question 5: A grant administrator at a university is offered a consulting contract by a vendor that supplies equipment to their federally funded project. This situation represents:
- A beneficial partnership that should be pursued
- A conflict of interest that must be disclosed and managed (Correct answer)
- A normal business practice in higher education
- An allowable arrangement if approved by the department chair
Correct answer: A conflict of interest that must be disclosed and managed
A financial relationship with a vendor supplying grant-funded goods creates a conflict of interest that must be disclosed to the institution and managed per policy.
Question 6: Professional development activities most valuable for grant administrators include which of the following?
- Learning only the regulations specific to their current grant portfolio
- Broad training in federal regulations, audit standards, financial management, and ethical practices (Correct answer)
- Focusing exclusively on grant writing skills
- Attending only agency-specific webinars for their primary funder
Correct answer: Broad training in federal regulations, audit standards, financial management, and ethical practices
Effective professional development for grant administrators encompasses federal regulations, financial management, audit requirements, and ethical practices across all award types.
Question 7: When an organization's annual revenues from federal awards exceed $750,000, they are generally required to undergo which type of audit?
- A financial statement audit only
- A Single Audit under the Single Audit Act (Correct answer)
- An IRS Form 990 review
- A performance audit by the awarding agency
Correct answer: A Single Audit under the Single Audit Act
Organizations expending $750,000 or more in federal awards in a fiscal year must undergo a Single Audit pursuant to 2 CFR Part 200 Subpart F.
CGA Professional Development & Ethics 3
A grant administrator is asked by their supervisor to approve an expenditure they believe is unallowable under 2 CFR Part 200.
The appropriate ethical response is to: