CGMS 100%

Domain: Program Management

Lesson 4: Post-award: monitoring, reporting, and drawdowns

Running the grant day to day once the money starts moving · 14 practice questions

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Post-award is where a grants manager spends most working hours, day to day management of the money and the program once the award is signed. This course files this territory under NGMA's Program Management domain, though the payment mechanics also touch Fiscal Management: how funds move from the federal government to the organization, and how performance gets reported back. This lesson covers both halves, drawdowns and performance reporting, since they run on parallel but separate clocks.

Two ways federal money reaches an organization: advance and reimbursement

2 CFR 200.305(b) requires payment methods for recipients and subrecipients (other than States, which follow separate Treasury-State agreements) to minimize the time between the transfer of funds and their disbursement. Advance payment is the expected method: a recipient or subrecipient must be paid in advance if it maintains, or shows it is willing to maintain, written procedures that minimize that time and financial management systems that meet the standards for fund control and accountability. In other words, an organization should not draw money down and let it sit unspent in its bank account for long. Advance payments must be limited to the minimum amounts needed and timed with actual, immediate cash needs, not padded for convenience. Recipients must be able to submit payment requests as often as necessary when electronic funds transfers are used, or at least monthly when they are not.

Reimbursement, and the 30-day payment clock

Reimbursement is preferred when the conditions for advance payment cannot be met, when the federal agency or pass-through entity sets a specific condition under 200.208, when the recipient requests it, or when the award is for construction (or when a significant part of a construction project is privately financed or federally loaned and the federal award is a minor portion of it). Under reimbursement, the organization spends its own funds first and then requests payment back. The federal agency or pass-through entity must make payment within 30 calendar days after receiving the payment request, unless it reasonably believes the request to be improper (missing documentation, math errors, costs that look unallowable). For an organization managing cash flow carefully, understanding whether a given award runs on advance or reimbursement terms is not a technicality, it determines whether the organization needs its own working capital to float costs while waiting for reimbursement.

The working capital advance, a middle option

When an organization cannot meet the criteria for advance payment, and the federal agency or pass-through entity has determined that reimbursement is not feasible because the organization lacks sufficient working capital, 200.305(b)(4) allows a working capital advance: the payer advances cash to cover the organization's estimated disbursement needs for an initial period, generally aligned to its disbursing cycle, and after that reimburses its actual cash disbursements.

Performance reporting: what has to connect to what

2 CFR 200.329 governs monitoring and reporting program performance, and its central requirement is that, when reporting program performance, the recipient or subrecipient must relate financial data and project or program accomplishments to the performance goals and objectives of the award, and provide cost information (such as unit costs) when the award's terms require it. As applicable, a performance report should compare accomplishments to the objectives of the award for the period, explain why established goals or objectives were not met, and explain any cost overruns or higher-than-expected unit costs. Financial reporting alone (how much was spent) does not satisfy this requirement; the report has to show what that spending accomplished.

Reporting frequency: the floor and the ceiling

2 CFR 200.329 sets a floor and a ceiling on how often performance reports can be required: no less often than annually and no more often than quarterly, except when a specific condition under 200.208 applies. Annual reports are due no later than 90 calendar days after the reporting period, and quarterly or semiannual reports no later than 30 calendar days after it. Financial reports under 200.328 (the SF-425 at the time of publication) run on the same rhythm and deadlines. The final performance report is due no later than 120 calendar days after the period of performance ends for a direct recipient, and 90 calendar days for a subrecipient reporting to its pass-through entity, the same numbers as the final financial report, covered again in lesson 8 on closeout. The agency or pass-through entity may extend a due date with justification from the recipient or subrecipient.

What a pass-through entity does with subrecipient reports

When GCHS acts as a pass-through entity, passing federal funds on to its own subrecipients, 200.332(e) requires it to monitor each subrecipient as necessary to make sure it complies with the requirements and achieves the goals of the subaward, not just submits paperwork on time. That includes reviewing its financial and performance reports and making sure it takes corrective action on significant developments, such as audit findings and adverse conditions it reports. Under 200.329(f), a pass-through entity may conduct in-person or virtual site visits as warranted. The waiver in 200.329(g) for a performance report that is not needed to show that the award's goals are being achieved is written for the federal agency, so GCHS should ask its own awarding agency rather than skip a required report on its own.

Significant developments between reports

Between report due dates, 200.329(e) requires a recipient or subrecipient to notify the federal agency or pass-through entity of a significant development that could affect the award. That includes good news, such as reaching milestones sooner or at less cost than expected, and problems, delays, or adverse conditions that will affect its ability to meet milestones or objectives. When a development hurts the award, the notice has to include the plan for corrective action and any help needed to resolve it.

Payment methods and the reporting cycle Two parallel tracks: on the left, the payment method choice between advance payment (drawn down as needed, disbursed quickly) and reimbursement (organization spends first, gets paid back within 30 days); on the right, the reporting cycle running no less than annually and no more than quarterly, connecting financial data to program accomplishments. Payment methods (200.305) Advance payment Drawn as needed, spent promptly Reimbursement Org spends first, paid back within 30 calendar days Reporting cycle (200.329) Annual (floor) Due within 90 days of period end Quarterly (ceiling) Due within 30 days of period end Reports must connect $ spent to what it accomplished
Payment method and reporting frequency run on separate rules, but both exist to keep the money and the results connected.

Practice questions

1. Under 2 CFR 200.305(b), which payment method applies when an organization maintains written procedures that minimize the time between drawing down funds and disbursing them, and meets the fund-control standards?

  1. Advance payment
  2. Reimbursement only
  3. Working capital advance only
  4. Neither method is preferred; the choice is random

2. Once a proper reimbursement request is submitted, how quickly must the federal agency or pass-through entity make payment?

  1. Immediately, same day
  2. Within 90 calendar days
  3. Within 30 calendar days, unless the agency reasonably believes the request is improper
  4. There is no deadline

3. When is reimbursement, rather than advance payment, the preferred method?

  1. Only for awards under $10,000, where the paperwork for an advance would cost more than the award itself
  2. When advance conditions cannot be met, when the agency sets a specific condition, or for construction
  3. Reimbursement is never preferred
  4. Only for subrecipients, never for direct recipients

4. What is a working capital advance?

  1. A permanent grant supplement
  2. An indirect cost recovery mechanism
  3. A penalty imposed on a recipient after an audit finding, requiring it to return unspent cash within an initial period set by the agency
  4. Cash advanced for estimated disbursements over an initial period, when reimbursement is not feasible for lack of working capital

5. Which section of 2 CFR 200 governs monitoring and reporting program performance?

  1. 200.329
  2. 200.403
  3. 200.112
  4. 200.501

6. What must a performance report do, beyond stating how much money was spent?

  1. Nothing more; a total of dollars spent is a complete performance report if an authorized official certifies it is accurate and submits it on time
  2. Relate financial data to accomplishments, compare results to goals, and explain unmet objectives or overruns as applicable
  3. Only list the names of staff who worked on the grant
  4. Include a Single Audit report

7. Under 200.329, what is the least frequent a performance report can be required (the floor), and its deadline?

  1. Monthly, within 10 days
  2. Quarterly, within 30 days
  3. Annually, within 90 calendar days of the period end
  4. Once every 5 years

8. Under 200.329, what is the most frequent a performance report can generally be required (the ceiling, absent special conditions)?

  1. Quarterly, within 30 calendar days of the period end
  2. Weekly
  3. Annually only
  4. There is no ceiling; agencies can require daily reports

9. Under 2 CFR 200.332(e), what must a pass-through entity do when monitoring a subrecipient?

  1. Nothing; performance monitoring is solely the subrecipient's own responsibility
  2. Monitor as necessary to ensure compliance and that the subaward's goals are met, including reviewing reports and requiring corrective action
  3. Only review subrecipient performance once, at closeout, by comparing final expenditures to the approved budget and sending the subrecipient a summary letter
  4. Automatically terminate any subrecipient that misses a report deadline

10. Under 2 CFR 200.329(g), who may waive a performance report that is not necessary to ensure an award's goals and objectives are being achieved?

  1. The federal agency, when it decides the report is not needed
  2. No one; every required report must always be collected regardless of its usefulness
  3. Only NGMA can grant such a waiver
  4. The subrecipient itself, once it has submitted three reports

11. GCHS draws down CDBG funds and lets them sit in its operating account for six weeks before disbursing them to a subrecipient. Does this align with 200.305's advance payment expectations?

  1. Yes, there is no limit on how long advanced funds can sit before disbursement as long as they are recorded in the general ledger
  2. No, advance payment procedures are supposed to minimize the time between drawdown and disbursement, not let funds sit idle
  3. Yes, as long as the funds are in an interest-bearing account
  4. This is only a problem for construction awards

12. Why does understanding whether an award runs on advance or reimbursement terms matter operationally for an organization like GCHS?

  1. It doesn't matter; the two methods are functionally identical for cash flow and differ only in the name of the form used to request funds
  2. It only matters for construction grants
  3. It determines the CGMS exam domain the award falls under
  4. Reimbursement requires the organization to have working capital to cover costs while waiting to be paid back; advance payment does not

13. What deadlines does a final performance report generally follow, matching the closeout reporting deadlines covered in lesson 8?

  1. 120 days after the period of performance ends for a direct recipient, 90 days for a subrecipient
  2. 30 days for everyone, no exceptions
  3. One year for everyone, no exceptions
  4. There is no deadline for a final report

14. A recipient learns midway between report due dates that a permit delay will keep it from meeting a project milestone. What does 200.329(e) require?

  1. Nothing until the next scheduled report is due
  2. Waiting to notify the agency until the delay has lasted a full quarter, then including it in the next performance report
  3. Notifying the federal agency or pass-through entity, with a plan for corrective action and any help needed
  4. Ending the award and returning all funds drawn to date

Glossary

2 CFR 200.305
The Uniform Guidance section on federal payment methods: advance payment, reimbursement, and working capital advances.
2 CFR 200.328
The Uniform Guidance section on financial reporting: reports no less than annually and no more than quarterly, unless a specific condition applies.
Advance payment
Funds paid before they are spent, limited to the minimum amounts needed and timed with immediate cash needs.
Reimbursement
A payment method where the organization spends its own funds first and is paid back, generally within 30 calendar days of a proper request.
Working capital advance
Cash advanced to cover an organization's estimated disbursements for an initial period when it cannot yet operate on reimbursement.
2 CFR 200.329
The Uniform Guidance section on monitoring and reporting program performance, including reporting frequency floors and ceilings.
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