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On December 26, 2013, the Office of Management and Budget (OMB) effectively consolidated and streamlined these administrative requirements for not-for-profit entities into what has been referred to as the "Supercircular".
One of the most significant changes and most widely commented upon during the rule making process was the more stringent requirements for Subrecipient monitoring. These new requirements create a significant administrative burden for organizations to overcome. Given the timeframe for implementation (December 24, 2014) organizations need to not only understand these new requirements, but develop and implement processes to achieve compliance while ensuring any additional costs are recoverable.