We're back! Welcome to Season 3 of Grants Management Experts.

This season, I'm digging into one of the topics that trips up even seasoned grant professionals: Subpart E, Cost Principles of 2 CFR Part 200. If you've ever second-guessed whether a cost is allowable, wondered how to split direct from indirect costs, or felt lost trying to figure out your indirect cost rate, this season is for you.

Here's what I'm covering:

• What actually makes a cost allowable and reasonable
• The real difference between direct and indirect costs (and why it matters more than you think)
• Indirect cost rates and how to recover more of what you're owed
• What documentation auditors actually want to see

I've spent over 20 years working with nonprofits as an accountant and consultant, and since 2014 I've helped organizations negotiate indirect cost rates that have brought in an estimated $500,000+ in additional revenue. So this isn't theory, it's the stuff I deal with in real client work every day, and I'm excited to bring it to you.

To me, grants management isn't just about staying compliant. Done right, it's how we protect our funding, build trust with our funders, and make sure every dollar actually goes toward the mission.

I've got new episodes dropping throughout the season, so subscribe so you don't miss one. And if there's a topic or question you want me to cover, send it my way, I'd love to hear from you.

Connect with Jasmine & Markanday Consulting:

• Instagram: ⁠@markandayconsulting⁠
• LinkedIn: ⁠@markandayconsulting
• Website: www.markanday.consulting

In this season finale of Grants Management Experts, Jasmine Markanday wraps up Season 2 with one of the most crucial and often daunting areas of federal grant management: when things go wrong in federal grants.

Under 2 CFR 200.339–343, Jasmine explains the federal remedies available when a recipient or subrecipient fails to comply with grant requirements from temporary suspensions to full terminations and how you can protect your organization through proactive compliance, strong internal controls, and effective communication.

What You’ll Learn in This Episode 

The consequences of non-compliance:

• How federal agencies can withhold payments, disallow costs, or suspend/terminate awards
• The impact of termination listings in SAM.gov and how it affects future funding opportunities

Understanding termination:

• The three ways termination can occur: by the agency, mutual consent, or by the recipient
• What a termination notice must include reasons, effective dates, and scope
• Why transparency and procedural fairness (2 CFR 200.341–.342) matter in the appeals process

The financial impact:

• What happens to costs incurred during suspension or termination (hint: most are unallowable)
• The two limited exceptions that may apply
•  How suspension or termination halts your ability to charge costs to the award

How to protect your organization:

•  Strengthening internal controls and training staff
• Documenting compliance, communication, and corrective actions

• Understanding your right to object, appeal, and provide evidence before termination decisions are final

Key Takeaways

• Know the risks: Non-compliance can lead to more than disallowed costs; it can result in termination, SAM.gov reporting for five years, and future funding loss.

• Act quickly: If you receive a notice, respond immediately and explore corrective actions.

• Prevention is everything: Strong internal controls, policies, and staff training are your best defense.

Resources & Links

• 2 CFR 200.339–343: Remedies for Non- Compliance

• Learn more at markanday.consulting

Connect with Us

• Instagram: @markandayconsulting
• LinkedIn: @markandayconsulting
  

If this episode was helpful, please share it with your colleagues and leave a review to help other grant professionals find the show.

That’s a wrap for Season 2! Join Jasmine next season as she continues unpacking practical insights, compliance strategies, and expert guidance to help you stay informed and stay compliant.

Quote to Remember: “Grants management isn’t just about going after the money, it's about protecting your organization, the communities you serve, and the trust they’ve placed in you.” - Jasmine Markanday

In this episode of Grants Management Experts, Jasmine dives into one of the most practical — and often misunderstood — areas of federal grant management: procurement standards under 2 CFR 200.320. Whether you’re a recipient, subrecipient, or grants professional supporting compliance, understanding procurement methods is critical for both cost allowability and audit readiness.

What You’ll Learn in This Episode

1. The three procurement methods:

• Informal (micro-purchases & simplified acquisitions)
• Formal (sealed bids & proposals)
• Non-competitive (sole source under limited circumstances)
  

2. Key thresholds you must know:

• Micro-purchase threshold: $10,000, increasing to $15,000 on October 1, 2025
• Simplified acquisition threshold: $250,000, rising to $350,000 in October 1, 2025Self-certification option to raise micro-purchase thresholds up to $50,000 — and the conditions required
  

3. How to apply each method:

• When micro-purchases are appropriate and how to document price reasonableness
• Conditions for sealed bids versus proposals under the formal method
• Situations where sole sourcing is allowed — and the documentation required
  

4. Special considerations:

• Procurement of architectural and engineering services through qualifications-based selection
• State, local, or tribal rules that may further limit thresholds
• The importance of self-certification and internal risk assessments

In this episode of Grants Management Experts, Jasmine Markanday breaks down one of the most critical concepts in federal grant compliance: direct costs. Guided by 2 CFR 200.413, Jasmine explains what qualifies as a direct cost, when certain costs can shift from indirect to direct, and why consistency is the cornerstone of compliance.

From administrative staff salaries to minor purchases, unallowable costs, and nonprofit-specific considerations, this episode equips you with the clarity to correctly classify expenses and avoid compliance pitfalls. Whether you’re writing a grant budget or managing one post-award, this deep dive will help you protect your organization’s resources and credibility.

What You’ll Learn:

• The definition of direct costs under 2 CFR 200.413 and how they differ from indirect costs.

• Key questions to ask when deciding if an expense is a direct cost.

• Special conditions for charging administrative and clerical salaries directly.

• How to handle minor items and apply consistent treatment.

• The role of unallowable costs in calculating indirect cost rates.

• Nonprofit-specific rules for member and client service activities.
  

Key Takeaways:

• A cost is direct if it can be specifically tied to a grant’s objectives with accuracy.

• Consistency is non-negotiable—similar costs must be treated the same way across funding sources.

• Some typically indirect expenses (like cybersecurity upgrades) can be charged directly if they clearly support one grant.

• Administrative salaries may only be charged directly if they meet all three CFR conditions.

• Unallowable costs, while not chargeable, must still be included in the direct cost base for rate calculations.
  

Pro Tip:Train your staff on cost classification policies—misclassification can lead to audit findings, repayment of funds, and loss of credibility.

Connect with Us:

• Instagram: @markandayconsulting

• LinkedIn: @markandayconsulting

Enjoyed this episode? Leave a review, subscribe, and share it with your grants team!

Quote to Remember:

“Direct costs aren’t just about accuracy—they’re about fairness to your organization, your funders, and the federal government.” — Jasmine Markanday

In this episode of Grants Management Experts, Jasmine Markanday breaks down one of the most critical concepts in federal grant compliance: direct costs. Guided by 2 CFR 200.413, Jasmine explains what qualifies as a direct cost, when certain costs can shift from indirect to direct, and why consistency is the cornerstone of compliance.

From administrative staff salaries to minor purchases, unallowable costs, and nonprofit-specific considerations, this episode equips you with the clarity to correctly classify expenses and avoid compliance pitfalls. Whether you’re writing a grant budget or managing one post-award, this deep dive will help you protect your organization’s resources and credibility.

What You’ll Learn:

• The definition of direct costs under 2 CFR 200.413 and how they differ from indirect costs.

• Key questions to ask when deciding if an expense is a direct cost.

• Special conditions for charging administrative and clerical salaries directly.

• How to handle minor items and apply consistent treatment.

• The role of unallowable costs in calculating indirect cost rates.

• Nonprofit-specific rules for member and client service activities.
  

Key Takeaways:

• A cost is direct if it can be specifically tied to a grant’s objectives with accuracy.

• Consistency is non-negotiable—similar costs must be treated the same way across funding sources.

• Some typically indirect expenses (like cybersecurity upgrades) can be charged directly if they clearly support one grant.

• Administrative salaries may only be charged directly if they meet all three CFR conditions.

• Unallowable costs, while not chargeable, must still be included in the direct cost base for rate calculations.
  

Pro Tip:Train your staff on cost classification policies—misclassification can lead to audit findings, repayment of funds, and loss of credibility.

Connect with Us:

• Instagram: @markandayconsulting

• LinkedIn: @markandayconsulting

Enjoyed this episode? Leave a review, subscribe, and share it with your grants team!

Quote to Remember: “Direct costs aren’t just about accuracy—they’re about fairness to your organization, your funders, and the federal government.” — Jasmine Markanday

In this episode, Jasmine Markanday dives into one of the most fundamental yet confusing areas of federal grant compliance: understanding what costs are allowable under 2 CFR 200.403.

From budgeting to closeout, Jasmine breaks down the criteria that determine whether an expense can be charged to your award, explains how consistency and documentation protect your organization, and shares practical examples to help you apply the rules with confidence. Whether you’re new to grants management or a seasoned professional, this episode provides clarity on the building blocks of compliant cost management.

What You’ll Learn:

• The seven key factors that make a cost allowable under 2 CFR 200.403.

• Why “necessary and reasonable” is the foundation of cost allowability.

• How to identify costs excluded by your grant’s terms and conditions.

• The role of organizational policies and procedures in ensuring consistency.

• Documentation best practices that safeguard you during audits.

• Administrative closeout costs—what’s permitted and how to manage them.
  

Key Takeaways:

• Always ask: is this expense essential to achieving the project’s goals?

• Costs must conform to award terms, exclusions, and organizational policies.

• Consistency in financial treatment builds accountability and audit readiness.

• “Document, document, document”—good records are your best defense.

• Closeout costs are allowable, but must be liquidated before the final report.

  
  

Pro Tip: Don’t wait until the audit to figure out cost allowability review award terms and set up compliance-friendly systems from the very beginning.

Connect with Us:

• Instagram: @markandayconsulting

• LinkedIn: @markandayconsulting

  
  

Enjoyed the episode? Leave a review and share with your grants team!

Quote to Remember: “Planning, consistency, and documentation will be the key on your grants management journey.” — Jasmine Markanday

In this episode, Jasmine Markanday unpacks one of the most confusing compliance areas for grant recipients: how to correctly classify a partner as a subrecipient or a contractor under 2 CFR 200.331.

From avoiding costly audit findings to building monitoring plans, Jasmine walks through the rules, real-life examples, and documentation tips every grants professional needs to confidently manage pass-through funding. Whether you’re with a nonprofit, university, or public agency, if you work with subawards or contracts, this episode is for you.

What You’ll Learn:

• How to determine if an entity is a subrecipient or a contractor under 2 CFR 200.331.
• Why proper classification protects your funding and your organization.
• Monitoring requirements for subrecipients, from risk assessments to site visits.
• Contractor compliance essentials, including procurement standards and invoice accuracy.
• Common pitfalls in pass-through funding and how to avoid them.
• What to include in subaward agreements to ensure compliance and accountability.

Key Takeaways:

• Misclassifying a partner can lead to audit findings, penalties, or funding loss.
• Subrecipients carry out a portion of the federal award and are subject to program compliance; contractors provide goods/services and operate in a competitive market.
• Use a classification checklist to document your decision-making process.
• Build monitoring plans for subrecipients that include regular reviews, clear deliverables, and risk-based oversight.
• Tailor agreement templates for each subaward or contract to spell out responsibilities, reporting, and compliance requirements.

Pro Tip:

Don’t guess when classifying — use documented criteria and keep your reasoning on file. This not only supports compliance but also strengthens your defense in the event of an audit.

Connect with Us:

Instagram: @markandayconsulting

LinkedIn: @markandayconsulting

Enjoyed the episode? Leave a review and share with your grants team!

Quote to Remember:

"Funders may not say it plainly, but they will hold you accountable for how you classify and manage subrecipients and contractors." — Jasmine Markanday

In this episode, Jasmine Markanday breaks down a topic that often flies under the radar for grant recipients: intangible property under 2 CFR 200.315.

From ownership rules to copyright rights, research data transparency, and public access obligations this episode is packed with need-to-know insights for grant professionals managing digital or intellectual assets. Whether you're a nonprofit, university, or public agency, if your grant work includes reports, websites, or research, this one’s for you.

What You'll Learn:

• What qualifies as “intangible property” under 2 CFR 200.315.
• The rules around ownership and proper use of federally funded intangible property.
• Why “encumbering” intangible assets without approval is a compliance risk.
• Copyright guidance for grant-funded materials and what rights federal agencies retain.
• What counts as “research data” and how FOIA (Freedom of Information Act) applies.
• The distinction between protected data (drafts, trade secrets) and publicly shareable data.
• Best practices for managing public access expectations and protecting sensitive info.

Key Takeaways:

• If you acquire intangible property with federal funds, you own it but you must use it for the grant’s authorised purpose.

• You can copyright your work, but the federal government retains royalty-free, irrevocable rights to use and share it.
• Research data cited in federal rulemaking may be subject to public disclosure.
• Prepare early with clear data management plans to protect your organisation and remain compliant.
• Public access isn’t just a suggestion, it's a condition of funding. Collaborate with your funding agency to meet expectations.

Pro Tip:

Get legal and compliance teams involved early in the process especially when your grant involves publishing data or creating digital content. Planning from day one helps ensure secure and compliant handling of your intangible assets.

Connect with Us:

• Instagram: ⁠@markandayconsulting⁠

• LinkedIn: ⁠@markandayconsulting⁠

• Enjoyed the episode? Leave a review and share with your grants team!

Quote to Remember:

"You can’t sell, restrict, or repurpose grant-funded intellectual property without federal approval." — Jasmine Markanday

In this episode, Jasmine dives into a detail that often gets overlooked at the end of a federal grant: what to do with leftover supplies. If your organization has a closet full of unused materials at closeout, this one’s for you. Learn what counts as a “supply” under 2 CFR, how new federal thresholds might affect your next audit, and the steps you need to take to stay compliant.

What You'll Learn:

• The updated federal threshold for supply value—from $5,000 to $10,000 as of October 1, 2024.

• What qualifies as a “supply” versus “equipment” under 2 CFR.

• When you need to repay the federal government for unused supplies.

• How to calculate what’s owed based on your grant’s funding percentage.

• Allowable deductions for selling or handling costs.

• Best practices for documenting internal re-use of leftover items.

• A compliance reminder for subrecipients on using supplies in fee-based services.

  
  

Key Takeaways:

• Supplies left over at closeout aren’t just yours to keep—you may owe the federal government if the total value exceeds the applicable threshold.

• Always check your grant's start date and terms to determine which threshold applies.

• Selling the supplies? You can deduct up to $1,000 in reasonable handling costs.

• Clear documentation and communication with your program officer are key.

• Don’t undercut market rates if using federally funded supplies for services—that’s a compliance risk.

  
  

Pro Tip: Even if your leftover supplies don’t exceed the threshold, documenting how they’re reassigned or disposed of is a best practice that could save you headaches during audits.

Connect with Us:

• Instagram: @markandayconsulting

• LinkedIn: @markandayconsulting

• Enjoyed the episode? Leave a review and share with your grants team!

  
  

Quote to Remember: "Strong grant management isn’t just about winning grants—it’s about closing them the right way." — Jasmine Markanday

Are you navigating the world of grants or looking to step into a grant management role with clarity and confidence? Season 2 of Grants Management Experts is here to guide you through the ins and outs of grant compliance, policies, and procedures—without the overwhelm.

Hosted by Jasmine Markandey, a certified expert with deep experience across nonprofits, government agencies, tribal nations, and higher education, this season breaks down what it really takes to manage grants effectively from post-award to audit readiness.

You’ll get real-world insights, practical advice, and stories from the field to help you:

• Build stronger systems

• Avoid costly compliance mistakes

• Maximize the impact of your funding

  
  

Whether you’re new to grants or a seasoned pro, this podcast will help you stay on top of your game. Hit subscribe and get ready to become grant compliant—one episode at a time.