Grant Writing Post-Award Grant Management 3 — Questions and Answers
Question 1: Under Uniform Guidance, which of the following is an allowable cost principle that all federal grant expenditures must meet?
- Costs must be incurred after the grant period ends
- Costs must be reasonable, allocable, and allowable under the award (Correct answer)
- Costs must be approved by the funder's board
- Costs must only cover direct expenses, never indirect
Correct answer: Costs must be reasonable, allocable, and allowable under the award
2 CFR 200 requires that all costs charged to federal awards be reasonable, allocable to the award, and allowable under the applicable cost principles.
Question 2: What is the purpose of a single audit (2 CFR 200 Subpart F)?
- To evaluate the quality of the grant narrative for future awards
- To provide an independent examination of a non-federal entity's federal expenditures above the threshold (Correct answer)
- To audit the federal agency's distribution of grant funds
- To assess programmatic outcomes of funded projects
Correct answer: To provide an independent examination of a non-federal entity's federal expenditures above the threshold
A single audit is an organization-wide audit required when a non-federal entity expends $1,000,000 or more in federal funds in a fiscal year, covering both financial statements and federal award compliance.
Question 3: A grant manager notices a vendor invoice was charged to the wrong grant. What should she do first?
- Ignore it if the total budget is not exceeded
- Process a cost transfer with proper documentation and justification (Correct answer)
- Delete the charge from the accounting system
- Wait until the annual audit to correct it
Correct answer: Process a cost transfer with proper documentation and justification
A documented cost transfer is the proper mechanism to move an erroneous charge from one account to another, with timely correction and a clear justification trail.
Question 4: Which federal agency oversees the Uniform Guidance (2 CFR 200) framework for federal grant management?
- The Government Accountability Office (GAO)
- The Office of Management and Budget (OMB) (Correct answer)
- The Congressional Budget Office (CBO)
- The Federal Reserve
Correct answer: The Office of Management and Budget (OMB)
The Office of Management and Budget (OMB) issued and oversees 2 CFR 200, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
Question 5: An organization's indirect cost rate agreement has expired. What is the safest approach for charging indirect costs to a new federal award?
- Use the previous year's approved rate until a new one is negotiated (Correct answer)
- Stop charging indirect costs entirely
- Charge the maximum allowable rate without an agreement
- Use another organization's rate as a benchmark
Correct answer: Use the previous year's approved rate until a new one is negotiated
Many agencies permit the use of the most recently approved indirect cost rate on a provisional basis while a new rate is being negotiated, but this should be confirmed with the awarding agency.
Question 6: What is the key difference between a grant 'modification' and a grant 'amendment'?
- They are interchangeable terms with no practical difference
- A modification is initiated by the recipient; an amendment is a formal change to the award document itself (Correct answer)
- A modification increases the budget; an amendment extends the timeline
- Amendments apply only to state grants; modifications apply to federal grants
Correct answer: A modification is initiated by the recipient; an amendment is a formal change to the award document itself
While terminology varies by funder, a modification typically refers to recipient-initiated changes in scope or budget, whereas an amendment is a formal revision to the executed award document issued by the grantor.
Question 7: What does 'subrecipient monitoring' require of a pass-through entity?
- Conducting annual on-site visits to every subrecipient regardless of risk
- Ensuring subrecipients comply with federal requirements and verifying that activities are performed as agreed (Correct answer)
- Paying subrecipients directly without reviewing their invoices
- Allowing subrecipients to self-certify compliance without oversight
Correct answer: Ensuring subrecipients comply with federal requirements and verifying that activities are performed as agreed
Pass-through entities are responsible under 2 CFR 200.332 for monitoring subrecipient activities to ensure compliance with federal award requirements and that performance goals are met.
Under Uniform Guidance, which of the following is an allowable cost principle that all federal grant expenditures must meet?