In our last blog, we talked about how to avoid Uniform Guidance Audit (UGA) findings in your relationship with Direct Subcontractors. In this blog, we’ll focus on Direct Consultants.
The big difference between a direct subcontractor and a direct consultant is that a subcontractor is seen as a co-investigator in your project, with a designated scope of work. A consultant usually plays a less critical role but may still be important enough to be specifically named in the award, though they may not be. A direct consultant is a vendor that your company has hired for an ancillary good or service.
A direct consultant is working on your project and the government is reimbursing you for that work. It is your responsibility to make sure this relationship is in compliance with the FAR.
Your auditor will ask to see your consultant agreement, and will expect it to include the following:
Naturally, this consultant agreement should be signed.
You will be asked to produce invoices from your consultant, and your auditor will check to make sure that these invoices include the following information:
Often, direct consultants aren’t monitored as closely as employees because they are thought of as vendors. This can lead to problems because, as a rule, direct consultants aren’t as familiar with the FAR or the rules relating to your grant and can have poor billing practices.
Here are some of the most common findings UGA auditors find in direct consultant relationships:
Managing direct consultant relationships properly can become overwhelming when you have multiple consultants working on your project if you haven’t created the right checks and balances.
If you’re concerned about compliance and surviving a Uniform Guidance Audit, Contact Us to schedule a time to speak to one of our government funding experts, and we will follow up within 48 hours!
This is the fifth of our seven-part series about the Uniform Guidance Audit:
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