Grants and Cooperative agreements are different from FAR-based contracts. The Government includes a specific list of FAR/DFAR clauses in a FAR-based contract. However, under a grant, Federal Agencies generally include a reference to the entire 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

Government contractors must understand all 2 CFR 200 requirements to determine which are applicable to their grant. This can be especially difficult if you have both FAR-based contracts and grants. Keeping up with the differences between the two regulations is complex. Redstone GCI’s team of experts understands the differences in these regulations and has extensive experience with grant-based contractors to help you sort through the compliance and best practices.


  • Procurement Policies and Procedures – Purchasing materials, supplies, or even subcontracting services under a grant requires special attention under Federal Awards. Grants have different procurement policies and flowdowns for a subrecipient and a contractor.   Our team of specialists can assist your company in drafting or enhancing your procurement policies and procedures to ensure compliance.
  • Contractor vs. Subrecipient Determination – As a grant recipient, you have to manage and administer subaward to your vendors. Classifying a vendor as a contractor or subrecipient comes with different flow downs and requirements. We can assist you and your team in making the determination of contractor vs. subrecipient and documentation requirements.
  • Risk Assessment – A misstep in the appropriate identification of contractor vs subrecipient can impact the overall success of your grant. Our team can assist you in preparing a risk assessment questionnaire for subrecipients to determine the level of monitoring necessary to comply with grant regulations.
  • Accounting System – Having an accounting system structured to support the requirements of grant accounting is imperative. Our experienced consultants can assist you in ensuring your accounting system is designed so that it is capable of tracking direct and indirect costs and identifying unallowable costs in accordance with the grant regulations.
  • Accounting Policies and Procedures – We have a team of experts that can assist you in reviewing accounting policies and procedures for compliance with grant regulations.
  • Property Policies and Procedures – Grants including the use of property and assets ultimately paid for by the Government, have specific requirements for the treatment of this “Government Property.” If property is applicable to your grant, we can assist in developing or reviewing policies and procedures for tracking property in accordance with the grant regulations.
  • Grant Brief – Understanding your grant requirements is vital to success. We can assist you in preparing a detailed grant brief of terms and conditions, and reporting requirements from the multiple documents that make up the grant award (e.g., award, special terms and conditions, Federal Assistance Reporting Checklist, etc.).

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John C. Shire, CPAJohn C. Shire, CPA
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