(Recorded Webinar) Mandatory Disclosures
All Federal grantees must report certain activities potentially affecting their Federal award, including fraud and fraud-like matters, certain conflicts of interest, and relevant criminal, civil, and administrative proceedings.
Before the Uniform Guidance, much of this reporting was voluntary, but with the promulgation of the Uniform Guidance in December 2014, OMB has moved from voluntary disclosures 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 (the Federal Awardee Performance and Integrity Information System).
Understanding the scope of these reporting requirements is critical, yet the regulatory text is, in many places, ambiguous and there are a lot of questions about how to comply:
- When does an activity reach the point of required disclosure (e.g., immediately upon discovery or after an investigation)?
- What is considered "a timely manner" to report the matter?
- How do you determine that a violation has occurred or an issue potentially affects your Federal award and should be disclosed?
- Does your organization receive enough grant funds to trigger disclosures in FAPIIS?
This webinar will provide an overview of mandatory disclosures, FAPIIS, and how to make sure that your organization is prepared to comply.
To purchase the live version of this webinar or the live and on-demand package, click here.
- 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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- 1.25 Certificate of Attendance
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