Concurrent Sessions and Deep Dives

The most common compliance finding for federal grant recipients is a failure to adequately document the time and effort of the grantee’s personnel. Fundamentally a requirement designed to ensure reasonable allocation of personnel costs, time and effort requirements are often misunderstood. Compounding the confusion, the Uniform Guidance relaxed requirements for most grantees in late 2014, but the relaxed standards in the regulatory text led to few changes in actual practices by agency reviewers, auditors, and grantees who had grown accustomed to the more specific requirements under the prior OMB Circulars.