Manage Post Award Compliance And Reporting

---
name: manage-post-award-compliance-and-reporting
description: Keep an awarded federal grant clean from setup through closeout — run the 2 CFR 200 cost-principle test (allowable/allocable/reasonable) on every charge, establish and apply the indirect rate (NICRA vs de minimis on MTDC), keep time & effort certified, produce the SF-425 FFR and the RPPR/SF-PPR on the award calendar, make the 2 CFR 200.331 subrecipient-vs-contractor determination and stand up subrecipient monitoring, and carry the award to an audit-ready closeout (Single Audit threshold, documentation trail, final reports). Reach for this when the user asks "can we charge this cost?", "what indirect rate?", "build the FFR/RPPR", "subrecipient or contractor?", or "are we audit-ready?". Used by `grants-compliance-and-reporting-specialist` (primary). Not legal/accounting advice.
---

# Skill: manage-post-award-compliance-and-reporting

> **Invoked by:** `grants-compliance-and-reporting-specialist` (primary). Also consulted by `grants-strategy-lead` to confirm a proposal-stage commitment (indirect rate, subrecipient plan) is deliverable before it becomes binding.
>
> **When to invoke:** "Can we charge this cost to the grant?"; "what indirect rate can we charge?"; "build the FFR / RPPR"; "is this partner a subrecipient or a contractor?"; "are we audit-ready?"; "set up the compliance calendar / run closeout"; any post-award compliance or reporting move.
>
> **Output:** a cost-principle test, or an indirect-rate path, or the FFR/RPPR, or a subrecipient determination + monitoring plan + audit-readiness check — each cited, retrieval-dated, and captured in the compliance tracker. **Not legal/accounting advice.**

## Procedure

1. **Anchor the award terms first.** Capture the Assistance Listing/CFDA number, period of performance, total + indirect terms, cost-share/match, reporting cadence, and program-specific terms into [`../../templates/post-award-compliance-tracker.md`](../../templates/post-award-compliance-tracker.md). Compliance starts at setup, not the first report.
2. **Run the cost-principle test on every charge in question.** Under 2 CFR 200 Subpart E a federal cost must be **allowable** (permitted by the cost principles + the award; some costs are expressly unallowable), **allocable** (benefits the award in proportion charged), and **reasonable** (a prudent person would incur it). "We budgeted it" is not the test — document the rationale and cite the section (retrieval-dated). See [`../../knowledge/grants-management-patterns-2026.md`](../../knowledge/grants-management-patterns-2026.md).
3. **Establish the indirect rate before charging indirect.** Use a negotiated **NICRA** if one exists; otherwise the **de minimis** rate on **Modified Total Direct Costs (MTDC)** — historically 10%, **raised by recent Uniform Guidance revisions (widely reported up to 15%) → verify the current rate + effective date against eCFR before applying.** Apply to the correct base (MTDC excludes equipment, capital, the over-threshold portion of each subaward).
4. **Keep time & effort defensible.** Payroll charged to the award must be supported by records of **actual** work, **certified after the fact** — the single most-cited audit finding area. Set up the certification cadence now; never reconstruct effort from memory at year-end.
5. **Make the subrecipient-vs-contractor determination on substance.** Apply the five 2 CFR 200.331 characteristics (see the decision-tree doc) — a subrecipient carries out the program and is subject to compliance; a contractor provides goods/services in a competitive market. A subaward triggers **monitoring** (2 CFR 200.332: risk assessment, required flow-down terms, reviewing their reports, verifying their Single Audit, following up on findings); a contract triggers **procurement standards**. Document the call.
6. **Report on the calendar, from the tracker.** Build the **SF-425 FFR** (financial) and the **RPPR / SF-PPR** (performance) to the award's cadence, figures traced to the ledger. Track **drawdowns** against the period of performance and the advance/reimbursement method. A missed report jeopardizes the current draw and the next award.
7. **Stay audit-ready and close out.** Watch the **Single Audit** threshold (≥ the current figure in federal awards expended in a fiscal year — long $750K, **recently raised, widely reported to $1M → verify against eCFR**); keep the documentation trail continuously. At period end run the **closeout checklist**: final FFR, final performance report, equipment/property disposition, records retention, drawdown reconciliation.
8. **Name the seams and the caveats.** The ledger → `accounting-bookkeeping`; a finding tracing to an over-promised proposal → `grants-strategy-lead`. Flag every volatile figure with a retrieval date and flag where a licensed professional (CPA/attorney) is required. **Not legal/accounting advice.**

## Worked example

> User: "We won the state literacy grant (pass-through federal). Can we charge the program director's laptop, and what indirect rate applies?"

- **Award anchor:** pass-through federal → **2 CFR 200 applies**; capture PoP, reporting cadence (SF-425 semi-annual + final, SF-PPR annual), and indirect terms into the tracker.
- **Cost test on the laptop:** *Allowable?* — equipment/computing devices are allowable if the cost principles + award allow and it's not a general-purpose exclusion; *Allocable?* — only the portion used for the grant program (if shared, allocate by use); *Reasonable?* — a standard laptop, yes. Document the allocation rationale; cite 2 CFR 200 Subpart E (**retrieval-dated**). Note: a laptop over the equipment capitalization threshold is **excluded from the MTDC base** for indirect.
- **Indirect rate:** the org has **no NICRA** → elect the **de minimis** rate on **MTDC** (**verify current % — 10% historically, recently raised**). The laptop, if capital-equipment, drops out of MTDC before the rate applies.
- **Time & effort:** the director charges 40% effort to the grant → set up after-the-fact semi-annual certification of actual effort.
- **Caveat:** current de minimis rate and the equipment threshold are volatile — verify against eCFR before booking. **Not accounting advice — the org's CPA/auditor owns the final treatment.**

## Guardrails

- **"We budgeted it" is not allowability** — every charge passes allowable AND allocable AND reasonable, documented.
- **No indirect without a basis** — NICRA if you have one, de minimis on the correct MTDC base if you don't; never an invented percentage.
- **Time & effort is certified, after-the-fact, real** — not a year-end reconstruction (the top audit finding).
- **Subrecipient vs contractor is substance, not the title** — the determination decides whether you must monitor; get it wrong and inherit the finding.
- **The compliance calendar is day-one infrastructure** — a missed FFR/RPPR or a blown drawdown window is avoidable.
- **Every volatile federal figure carries a retrieval date** (de minimis rate, Single Audit threshold, MTDC exclusions, section numbers, form versions) — re-verify against eCFR / Grants.gov. **Not legal/accounting advice; flag when a CPA/attorney is required.**