With the promulgation of the Uniform Guidance in December 2014, OMB has moved from voluntary disclosures of fraud and fraud-like matters to mandatory reporting (2 C.F.R. § 200.113), and has begun to call for self-reporting of certain conflicts of interest in grant-supported transactions (2 C.F.R. § 200.112). As of January 2016, mandatory reporting expanded further with requirements under FAPIIS. Understanding the scope of these reporting requirements is critical, yet the regulatory text is, in many places, ambiguous. Join FTLF Partner Scott Sheffler to discuss these requirements and practical approaches to compliance.
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- Evaluate the Uniform Guidance mandatory reporting requirements, including possible strategies for interpreting ambiguous aspects
- Understand the scope of FAPIIS
- Discuss trends in grant-related self-disclosure requirements
A Partner with the firm in the Federal Grants and Health Law practice groups, Scott advises clients on matters of federal grant law, government contract law, and health care law. Scott assists clients with the myriad requirements that apply upon acceptance of federal grant funding, including the administrative requirements and cost principles established in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), the Office of Management and Budget (OMB) Circulars that preceded the Uniform Guidance, and program-specific statutory and regulatory funding conditions. [Full Bio]
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