Determining how to properly administer federal grants and federal grant funds can be confusing and challenging. Approximately 30 years ago, the federal Office of Management and Budget (“OMB”) attempted to clarify this murky area by issuing guidance to federal agencies on uniform administrative requirements for grants and agreements with institutions of higher education, hospitals, and nonprofit organizations in the form of Circular A-110, which has been codified in the Code of Federal Regulations at 2 CFR Part 215. In compiling this guide, CAPLAW reviewed decisions from the HHS Departmental Appeals Board (“DAB”) and other administrative appeal bodies. These administrative bodies hear appeals of decisions by federal funding sources to disallow costs, cancel grants, or take other adverse action against grant recipients. The decisions, case law, and audits included in this guide serve as informative vehicles for explaining the grant administrative requirements and their application to real world situations.
