Get Full Government Meeting Transcripts, Videos, & Alerts Forever!
Get email alerts on the Subrecipient Monitoring topic
No spam. Unsubscribe anytime.
OAA webinar: fiscal agents must keep separate accounting, monitor subrecipients and follow spending sequence
Summary
The Opioid Abatement Authority urged fiscal‑agent cities and counties to enforce written agreements, maintain separate accounting by funding source, prefer reimbursement payments to subrecipients, and be ready for operational reviews that could result in corrective actions or fund repayment.
The Opioid Abatement Authority used its Abatement Academy webinar to detail fiscal agent duties and subrecipient monitoring expectations for OAA‑funded projects, and to flag enforcement risks for jurisdictions that mix funds or fail to document expenses.
Sharika Bridges, OAA senior manager for grant operations, told attendees that fiscal agents are responsible for overall compliance of awards that pass through them and should require written agreements (MOUs or contracts) with any subrecipient. "As a fiscal agent of an OAA award, the fiscal agent is responsible for overall compliance of the grant, not the sub," she said, stressing the importance of clear roles and written documentation.
Accounting and spending sequence: Bridges emphasized the OAA’s separate‑accounting requirement: jurisdictions must track each funding source and, where multiple OAA buckets exist (individual distribution, gold standard, cooperative funds), keep them in distinct accounting buckets so expenses reconcile to the general ledger. She described a spending sequence that prioritizes non‑OAA matching funds first, then individual distribution and gold standard funds, with cooperative or competitive funds spent last.
Subrecipient monitoring: the OAA recommended frequent contact between fiscal agents and subrecipients (monthly preferred, quarterly minimum), documented budgets by line item, regular reconciliation of reported expenses to the locality ledger, and payment on a reimbursement basis where feasible to preserve invoice and documentation trails. Bridges said fiscal agents should not rely solely on subs to complete renewal applications or annual reports and should instead review and validate the information before submission.
Operational reviews and consequences: Bridges warned that OAA may conduct site visits or desk audits under its updated terms and conditions, and that mixing OAA funds or failing to maintain separate accounting could lead to a performance improvement plan, termination of award, repayment of funds, and limits on future eligibility. "The mixing of OAA funds with other funds, or even the mixing of the different types of OAA funds into one bucket is prohibited, and it could potentially result in a finding," she said.
Practical steps recommended: execute written operational agreements for cooperative partnerships, document performance measure benchmarks in subrecipient agreements, keep full procurement and invoice records, require subs to submit progress and financial reports, and notify OAA promptly about substantiated subrecipient noncompliance so OAA can assist with corrective action.
The webinar concluded with a list of regional OAA liaisons and a reminder that the slide deck and recording will be posted for reference.
