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DEPARTMENTAL MATTERS Agreements for Sub -Recipients of Federal Grant Awards In the audit exit conference this year, the external auditor recommended that Indian River County execute agreements with all grant sub -recipients, in accordance with 2 CFR 200, Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. This will also avert a written audit finding by the external auditor for non-compliance with federal grant requirements. The definition of sub -recipient from the Federal Uniform Grant Guidance Circular is: 200.93 Subrecipient. 1. Subrecipient means a non -Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency. Based on the classification of grant recipients in the Indian River County Comprehensive Annual Financial Report (CAFR), the SRA and the Treasure Coast Homeless Services Council are classified as grant sub -recipients. Characteristics which support the classification of the non - Federal entity as a subrecipient include when the non -Federal entity: (1) Determines who is eligible to receive what federal assistance; (2) Has its performance measured in relation to whether the objectives of a Federal program were met; (3) Has responsibility for programmatic decision making; (4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and (5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity. Recommendation: Staff recommends that grant sub -recipient agreements with the Senior Resource Association and the Treasure Coast Homeless Services Council be executed retroactive to October 1, 2016 for the existing year grant awards and for all future grant awards. Any future sub -recipients will also be required to complete grant sub -recipient 'agreements. A sample sub -recipient agreement is includes as Attachment C, and has been reviewed and approved by the external auditor. FUNDING Option 1 would provide FY 2017-18 Non Profit Agency funding of $159,707. This funding would be phased out completely in the FY2108-19 budget. Options 2 would grandfather Nonprofit Agency funding at $159,707 and cap future funding at this level. P133