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Baltimore updates grant rules to tighten federal subrecipient monitoring and UEI checks
Summary
The Board of Estimates approved two administrative manual additions from the cityBudget and Management Research Bureau requiring standardized subrecipient risk assessments, monitoring plans and verification of Unique Entity Identifiers for entities receiving federal funds.
The Baltimore City Board of Estimates approved two administrative manual revisions on Wednesday requiring standardized subrecipient monitoring and verification of Unique Entity Identifiers (UEI) for entities receiving federal awards.
BBMR(Bureau of Budget and Management Research) officials said the changes implement federal requirements in 2 CFR 200 and address inconsistencies the city identified in its grant processes. "These policies address what we have outlined in our corrective action plans," Grants Management Director Ashley Meyer said during the presentation.
The new AM 413-51 (grant subrecipient monitoring and management) requires city entities that subaward federal funds to verify that subrecipients maintain a valid UEI, are in good standing with the Maryland Department of Assessments and Taxation, and are not on the SAM.gov exclusion list. Agencies must perform an initial risk assessment for each subrecipient, adopt a monitoring plan based on that risk, and document monitoring results and reporting cadences with subrecipients.
The companion AM 413-21 (federal grants registration and UEI) directs agencies to coordinate UEI usage through the grants management office, maintain annual registration on SAM.gov, and ensure use of a consistent UEI when applying for or accepting federal awards. BBMR said the policies were drafted after a citywide grants needs assessment, agency working groups and trainings, and were posted for agency comment on the citySharePoint site.
Council President Zeke Cohen and Comptroller Bill Henry both commended the administrationfor responding to federal audit findings; Cohen noted that the rules aim to standardize practices that had previously varied across city agencies. The Board approved both items by voice vote.
Why this matters: BBMR said the measures implement federal Uniform Guidance requirements and are intended to reduce the city's audit risk and standardize documentation across agencies that receive and subaward federal grant funds. BBMR staff said the policy will supersede individual agency SOPs where they conflict and that law, the Small Business Office and the Board review will be part of the subaward approval process.
The Board approved SB2513214 (create AM 413-51, grant subrecipient monitoring and management) and SB2513213 (create AM 413-21, federal grants registration and UEI) with no dollar impact recorded on the agenda.
