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To: Accountability,
Efficiency, Transparency
MISSISSIPPI LEGISLATURE REGULAR SESSION 2026
By: Representative Ford (54th)
HOUSE BILL NO. 1171
(As Sent to Governor)
AN ACT TO CREATE THE MISSISSIPPI GRANT AND SUBGRANT 1
ADMINISTRATION TRANSPARENCY AND ACCOUNTABILITY OF NON-GOVERNMENTAL 2
ORGANIZATIONS ACT OF 2026; TO ESTABLISH THAT THIS ACT SHALL BE 3
CREATED TO ESTABLISH REQUIREMENTS THAT ENHANCE OVERSIGHT, 4
ACCOUNTABILITY AND TRANSPARENCY IN GRANT ADMINISTRATION OF STATE 5
AND FEDERAL FUNDS; TO DEFINE RELEVANT TERMS; TO ESTABLISH GRANT 6
PROGRAM PERFORMANCE METRICS AND REQUIREMENTS; TO ESTABLISH GRANT 7
ADMINISTRATION, FINANCIAL REPORTING AND LEADERSHIP DISCLOSURE 8
REQUIREMENTS; TO CLARIFY WHAT CONSTITUTES PROHIBITED ACTIVITIES 9
FOR THE USAGE OF GRANT FUNDS; TO PROVIDE INFORMATION THAT SHALL BE 10
SUBJECT TO AUDITS OF NON-GOVERNMENTAL ORGANIZATIONS AND 11
QUASI-PUBLIC ENTITIES; TO REQUIRE THAT REPORTS REQUIRED BY THIS 12
ACT SHALL BE FILED WITHIN 180 DAYS AFTER FISCAL END OF YEAR AND 13
AFTER OSA PERFORMS OR DIRECTS A COMPLIANCE AUDIT; TO AUTHORIZE DFA 14
TO ENFORCE THE POLICIES AND PROCEDURES OF THIS ACT; AND FOR 15
RELATED PURPOSES. 16
BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF MISSISSIPPI: 17
SECTION 1. (1) This act shall be known and may be cited as 18
the "Mississippi Grant and Subgrant Administration Transparency 19
and Accountability of Non-Governmental Organizations Act of 2026." 20
(2) It is the intent of the Mississippi State Legislature to 21
establish requirements that enhance oversight, accountability and 22
transparency in grant administration of state and federal funds 23
appropriated by the Mississippi State Legislature to 24
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Non-Governmental Organization grantees and subgrantees receiving 25
state and federal funds appropriated by the State Legislature. 26
SECTION 2. For the purpose of this act: 27
(a) "Grant" means an award of financial assistance 28
following a grant application process or other method of obtaining 29
state or federal funds appropriated by the State Legislature from 30
a state agency, board commission or other unit of government to an 31
eligible nongovernmental recipient for specified project-based 32
purposes. 33
(b) "State agency" means any executive 34
department, military department, government corporation, 35
government controlled entity, quasi-government entity, corporation 36
or other establishment in state government. 37
(c) "Primary recipient" means any entity 38
receiving grant funds appropriated by the State Legislature 39
directly from a state agency, except for an individual or 40
household. 41
(d) "Subrecipient" means an entity that receives a 42
subaward from a pass-through entity to carry out part of an award. 43
The term subrecipient does not include a beneficiary or 44
participant. A subrecipient may also be a recipient of other 45
federal or state awards directly from a federal or state agency. 46
Individual persons or households are not considered to be 47
subrecipients under this section. 48
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(e) "Subaward" means an award of state or federal funds 49
appropriated by the State Legislature provided by a pass-through 50
entity to a subrecipient for the subrecipient to contribute to the 51
goals and objectives of the project by carrying out part of a 52
state award received by the pass-through entity. It does not 53
include payments to a beneficiary or participant. 54
(f) "Pass-through entity" means a recipient or 55
subrecipient that provides a subaward to a subrecipient (including 56
lower-tier subrecipients) to carry out part of a federal or state 57
program. 58
SECTION 3. (1) All state agencies that administer grants 59
shall establish specific, measurable annual objectives and 60
outcomes relating to the purpose of the grant. 61
(2) Where appropriate, grant programs shall include 62
long-term performance objectives for at least five (5) years into 63
the future. 64
(3) Primary recipients shall annually submit summary 65
progress reports demonstrating advancement toward stated 66
objectives. 67
(4) Failure to meet reporting requirements or established 68
metrics, unless required otherwise by federal law, shall result 69
in: 70
(a) Immediate suspension of grant payments pending 71
corrective action; 72
(b) Agency review for potential grant termination; and 73
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(c) Termination of grant award if metrics remain unmet 74
in one hundred twenty (120) days following the due date of annual 75
report. 76
(5) The Department of Finance and Administration (DFA) shall 77
establish a schedule for periodic review of all state grant 78
programs. 79
(6) Each state agency shall conduct comprehensive reviews of 80
their existing grant programs every five (5) years, except for any 81
program not expected to last for more than two (2) years. 82
(7) Agencies shall submit recommendations to the Legislative 83
Budget Office (LBO) regarding continuation, modification, or 84
termination of reviewed programs at the conclusion of their 85
comprehensive reviews as set forth in Section 3(4)(b) of this act. 86
SECTION 4. (1) State agencies shall establish objective 87
criteria for grant eligibility. 88
(2) No preference shall be given based on: 89
(a) Political affiliation; 90
(b) Ideological orientation; 91
(c) Prior receipt of federal and state grants, except 92
with respect to documented violations of the prohibited activities 93
outlined in subsections (9) and (10) of this section, unless 94
required otherwise by federal law; or 95
(d) Organization type or tax status, unless 96
specifically required by federal law. 97
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(3) Grant eligibility shall not be restricted based on 98
organization type or tax status, unless: 99
(a) Explicitly required by federal or state law; or 100
(b) Determined necessary based on documented 101
programmatic requirements. 102
(4) Primary recipients shall submit detailed annual 103
financial reports, including: 104
(a) Summary of expenditures; 105
(b) Administrative costs; 106
(c) Complete accounting of all funds redistributed to 107
subrecipients; and 108
(d) The purpose for all funds redistributed to 109
subrecipients. 110
(5) Subrecipients shall submit detailed annual financial 111
reports, including: 112
(a) Summary of expenditures; 113
(b) Administrative costs; 114
(c) Direct service expenses; 115
(d) Supporting documentation for all expenses exceeding 116
Twenty-five Thousand Dollars ($25,000.00); 117
(e) Complete accounting of all funds redistributed to 118
any additional subrecipients; and 119
(f) The purpose for all funds redistributed to any 120
additional subrecipients. 121
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(6) Any nongovernmental organization applying for grant 122
funding or receiving grant funding of state or federal funds 123
appropriated by the State Legislature shall require all executive 124
officers and members of its governing board to submit a signed 125
disclosure statement that includes: 126
(a) Whether such individual currently serves in any 127
professional capacity with decision-making authority regarding 128
grant appropriations; 129
(b) Whether such individual has, within the preceding 130
five (5) years, served as an executive officer or member of a 131
governing board for an organization at a time when that 132
organization violated the reporting requirements of subsections 133
(4) and (5) of this section; 134
(c) Any criminal convictions for offenses related to 135
bribery, corruption, fraud or other financial crimes; and 136
(d) The nature, jurisdiction and disposition date of 137
any such conviction. 138
(7) Such disclosure statements shall: 139
(a) Be submitted with the initial grant application; 140
(b) Be updated within thirty (30) days of any change in 141
leadership or relevant circumstances; and 142
(c) Be certified as true and complete under penalty of 143
perjury. 144
(8) Failure to provide and timely update the disclosures in 145
subsection (6) of this section, will subject the primary recipient 146
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or subrecipient of immediate termination of grant funds and a 147
three-year debarment from receiving grant funds, including grant 148
subawards, unless otherwise required by federal law. 149
(9) Grant funds shall not be used by a primary recipient or 150
subrecipient for any partisan political activities, initiative or 151
referendum support or opposition, voter registration or 152
Get-Out-the-Vote Campaigns. 153
(10) Grant funds shall not be distributed to a primary 154
recipient or subrecipient with a common board member with a 155
grantee or subgrantee that provided the funds to the primary 156
recipient or subrecipient without written notice and disclosure of 157
the potential conflict to the grantee who provided the funds to 158
the primary recipient or subrecipient. 159
(11) Violation of subsections (9) and (10) of this section 160
will subject the primary recipient or subrecipient of immediate 161
termination of grant funds and a three-year debarment from 162
receiving grant funds, including grant subawards, unless otherwise 163
required by federal law. 164
(12) Any primary recipient or subrecipient must show no 165
grant funds were used indirectly or directly in an alleged 166
violation of subsections (9) and (10) of this section to avoid 167
sanctions. 168
SECTION 5. (1) Any Non-Governmental Organization (NGO) or 169
quasi-public entity that receives state or federal funds 170
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appropriated by the State Legislature as a grantee or subgrantee 171
shall be subject to a compliance audit. 172
(2) The audit shall include, at minimum: 173
(a) Schedule of Expenditures of State Funds (SESF) for 174
each: 175
(i) Payment date; 176
(ii) Amount; 177
(iii) Description/object code; 178
(iv) Vendor/payee legal name and persistent vendor 179
ID; 180
(v) Voucher ID; 181
(vi) Contract/Award ID; 182
(vii) PO/Release, if applicable; 183
(viii) Fund; and 184
(ix) Program/appropriation code; 185
(b) Schedule of Revenues by source: 186
(i) State-tax-derived funds; 187
(ii) Other state funds; and 188
(iii) Federal, local and private funds; 189
(c) Subrecipient schedule: 190
(i) Entity; 191
(ii) Employer Identification Number 192
(EIN)/Secretary of State (SOS) ID; 193
(iii) Amount; 194
(iv) Purpose; 195
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(v) Award/subaward ID; and 196
(vi) Dates; 197
(d) Related party transactions and conflict-of-interest 198
disclosures; and 199
(e) Findings with severity, questioned costs, 200
criteria/condition/cause/effect and a Corrective Action Plan (CAP) 201
with responsible official and timeline. 202
(3) Auditees shall provide full access to books and records, 203
including bank statements, contracts and amendments, payroll 204
registers, invoices and subawards. All required schedules shall 205
be delivered in machine-readable formats (CSV/JSON; Parquet as 206
appropriate) using the join-key fields. 207
(4) DFA shall publish the report, management letter, and 208
Corrective Action Plan (CAP) on Transparency Mississippi and 209
transmit them to the Legislative Budget Office (LBO). The report 210
shall identify any payments that appear to diverge from the 211
auditee's stated purposes or the statutory/contractual basis for 212
receiving public funds. 213
(5) Reports are due within one hundred eighty (180) days 214
after the fiscal end of year and after the Office of the State 215
Auditor (OSA) performs or directs a compliance audit, and the 216
Office of the State Auditor (OSA) shall retain these report 217
records for no less than seven (7) years. 218
(6) Failure to submit material noncooperation, or 219
obstruction authorizes, DFA may suspend payments, withhold new 220
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ST: Grants; increase oversight, accountability
and transparency in administration of by state
agencies.
awards or recoup funds, and authorizes the Office of the State 221
Auditor (OSA) to refer the matter to the Attorney General. 222
(7) The auditee's schedules and Corrective Action Plan (CAP) 223
shall be certified under penalty of perjury by an authorized 224
officer and certified public accountant. 225
SECTION 6. This act shall take effect and be in force from 226
and after January 1, 2027. 227