Category Archives: Subcontract Oversight & Compliance

Information on Corporate Contractor Performance and Integrity

The Department of Defense, General Services Administration, and National Aeronautics and Space Administration issued a final rule on March 7, 2016, that requires offerors to disclose within the Federal Awardee Performance and Integrity Information System (FAPIIS) information on any parent, subsidiary, or successor entities that held a Federal contract or grant within the last three years.   Continue reading Information on Corporate Contractor Performance and Integrity

OMB Circular – Proposed Guidance

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Reform of Federal Policies Relating to Grants and Cooperative Agreements; Cost Principles and Administrative Requirements (including Single Audit Act)

By: Mary Karen Wills

The complete text of this proposal and a crosswalk of policy changes from the existing guidance are available on the OMB website under Proposed Policies.

This guidance is applicable to grants and cooperative agreements that involve state, local, and tribal governments, as well as institutions of higher education and nonprofit organizations. The proposal rule seeks to consolidate and streamline the requirements from OMB Circulars A-21, -89, -110 and -122. In addition, Circulars -50, -89, -102, and -133 on audits would be consolidated and streamlined. This guidance seeks to minimize the burden associated with compliance and audits for the grants and cooperative agreements with the aforementioned organizations. The goal would be to replace these eight circulars with one document, resulting in a single set of rules across these entities that currently have varying degrees of requirements.

Continue reading OMB Circular – Proposed Guidance