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To: Accountability,
Efficiency, Transparency
MISSISSIPPI LEGISLATURE REGULAR SESSION 2026
By: Senator(s) Sparks
SENATE BILL NO. 2630
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 YEAR END OF YEAR 13
OSA PREFORMS OR DIRECTS A COMPLIANCE AUDIT; TO AUTHORIZE DFA TO 14
ENFORCE THE POLICIES AND PROCEDURES OF THIS ACT; AND FOR RELATED 15
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 grantee and subgrantees receiving 25
taxpayer dollars. 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
general or special funds from a state agency, board commission or 30
other unit of government to an eligible nongovernmental recipient 31
for specified project-based purposes. 32
(b) "State agency" means any executive 33
department, military department, government corporation, 34
government controlled, quasi government entity, corporation or 35
other establishment in state government. 36
(c) "Primary recipient" means any entity 37
receiving grant funds directly from a state agency, except for an 38
individual or household. 39
(d) "Subrecipient" means an entity that receives a 40
subaward from a pass-through entity to carry out part of an award. 41
The term subrecipient does not include a beneficiary or 42
participant. A subrecipient may also be a recipient of other 43
federal or state awards directly from a federal or state agency. 44
Individual person or household are not considered to be 45
subrecipients under this section. 46
(e) "Subaward" means an award provided by a 47
pass-through entity to a subrecipient for the subrecipient to 48
contribute to the goals and objectives of the project by carrying 49
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out part of a state award received by the pass-through entity. It 50
does not include payments to a beneficiary or participant. 51
(f) "Pass-through entity" means a recipient or 52
subrecipient that provides a subaward to a subrecipient (including 53
lower tier subrecipients) to carry out part of a federal or state 54
program. 55
SECTION 3. (1) All state agencies that administer grants 56
shall establish specific, measurable annual objectives and 57
outcomes relating to the purpose of the grant. 58
(2) Where appropriate, grant programs shall include 59
long-term performance objectives for at least five (5) years into 60
the future. 61
(3) Primary recipients shall annually submit summary 62
progress reports demonstrating advancement toward stated 63
objectives. 64
(4) Failure to meet reporting requirements or established 65
metrics shall result in: 66
(a) Immediate suspension of grant payments pending 67
corrective action; 68
(b) Agency review for potential grant termination; and 69
(c) Termination of grant award if metrics remain unmet 70
in one hundred twenty (120) days following the due date of annual 71
report. 72
(5) The Office of the State Auditor (OSA) shall 73
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establish a schedule for periodic review of all state grant 74
programs. 75
(6) Each state agency shall conduct comprehensive reviews of 76
their existing grant programs every five (5) years, except for any 77
program not expected to last for more than two (2) years. 78
(7) Agencies shall submit recommendations to the Legislative 79
Budget Office (LBO) regarding continuation, modification, or 80
termination of reviewed programs at the conclusion of their 81
comprehensive reviews as set forth in Section 3(4)(b). 82
SECTION 4. (1) State agencies shall establish objective 83
criteria for grant eligibility. 84
(2) No preference shall be given based on: 85
(a) Political affiliation; 86
(b) Ideological orientation; 87
(c) Prior receipt of federal and state grants, except 88
with respect to documented violations of the prohibited activities 89
outlined in subsection (4) of this section; or 90
(d) Organization type or tax status, unless 91
specifically required by federal law. 92
(3) Grant eligibility shall not be restricted based on 93
organization type or tax status unless: 94
(A) Explicitly required by federal or state law; or 95
(B) Determined necessary based on documented 96
programmatic requirements. 97
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(4) Primary recipients shall submit detailed annual 98
financial reports including: 99
(a) Summary of expenditures; 100
(b) Administrative costs; 101
(c) Complete accounting of all funds redistributed to 102
subrecipients; and 103
(d) The purpose for all funds redistributed to 104
subrecipients. 105
(5) Subrecipients shall submit detailed annual financial 106
reports, including: 107
(a) Summary of expenditures; 108
(b) Administrative costs; 109
(c) Direct service expenses; 110
(d) Supporting documentation for all expenses exceeding 111
Twenty-five Thousand Dollars ($25,000.00); 112
(e) Complete accounting of all funds redistributed to 113
any additional subrecipients; and 114
(f) The purpose for all funds redistributed to any 115
additional subrecipients. 116
(6) Any nongovernmental organization applying for grant 117
funding or receiving grant funding shall require all executive 118
officers and members of its governing board to submit a signed 119
disclosure statement that includes: 120
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(a) Whether such individual currently serves in any 121
professional capacity with decision-making authority regarding 122
grant appropriations; 123
(b) Whether such individual has, within the preceding 124
five (5) years, served as an executive officer or member of a 125
governing board for an organization at a time when that 126
organization violated the reporting requirements of subsections 127
(4) and (5) of this section; 128
(c) Any criminal convictions for offenses related to 129
bribery, corruption, fraud or other financial crimes; and 130
(d) The nature, jurisdiction and disposition date of 131
any such conviction. 132
(7) Such disclosure statements shall: 133
(a) Be submitted with the initial grant application; 134
(b) Be updated within thirty (30) days of any change in 135
leadership or relevant circumstances; and 136
(c) Be certified as true and complete under penalty of 137
perjury. 138
(8) Failure to provide and timely update the disclosures in 139
subsection (6) of this section, will subject the primary recipient 140
or subrecipient of immediate termination of grant funds and a 141
three-year debarment from receiving grant funds, including grant 142
subawards. 143
(9) Grant funds shall not be used by a primary recipient or 144
subrecipient for any partisan political activities, initiative or 145
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referendum support or opposition, voter registration or get-out 146
the-vote campaigns. 147
(10) Grant funds shall not be distributed to a primary 148
recipient or subrecipient with a common board member with a 149
grantee or subgrantee that provided the funds to the primary 150
recipient or subrecipient without written notice and disclosure of 151
the potential conflict to the grantee who provided the funds to 152
the primary recipient or subrecipient. 153
(11) Violation of subsections (9) and (10) of this section 154
will subject the primary recipient or subrecipient of immediate 155
termination of grant funds and a three-year debarment from 156
receiving grant funds, including grant subawards. 157
(12) Any primary recipient or subrecipient must show no 158
grant funds were used indirectly or directly in an alleged 159
violation of subsections (9) and (10) of this section to avoid 160
sanctions. 161
SECTION 5. (1) Any NGO or quasi-public entity that (1) 162
receives state-tax-derived funds or (2) is a subrecipient of state 163
funds shall be subject to a compliance audit by or under the 164
direction of the Office of the State Auditor (OSA) pursuant to 165
GAGAS. OSA may apply risk-based scoping and materiality and may 166
integrate this work with any required federal or state single 167
audit. 168
(2) The audit shall include, at minimum: 169
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(a) Schedule of Expenditures of State Funds (SESF) for 170
each: 171
(i) Payment-date; 172
(ii) Amount; 173
(iii) Description/object code; 174
(iv) Vendor/payee legal name and persistent Vendor 175
ID; 176
(v) Voucher ID; 177
(vi) Contract/Award ID; 178
(vii) PO/Release, if applicable; 179
(viii) Fund; and 180
(ix) Program/appropriation code; 181
(b) Schedule of Revenues by Source: 182
(i) State-tax-derived funds; 183
(ii) Other state funds; and 184
(iii) Federal, local and private funds; 185
(c) Subrecipient schedule: 186
(i) Entity; 187
(ii EIN/SOS ID; 188
(iii) Amount; 189
(iv) Purpose; 190
(v) Award/subaward ID; and 191
(vi) Dates; 192
(d) Related-party transactions and conflict-of-interest 193
disclosures; and 194
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(e) Findings with severity, questioned costs, 195
criteria/condition/cause/effect and a Corrective Action Plan (CAP) 196
with responsible official and timeline. 197
(3) Auditees shall provide full access to books and records, 198
including bank statements, contracts and amendments, payroll 199
registers, invoices and subawards. All required schedules shall 200
be delivered in machine-readable formats (CSV/JSON; Parquet as 201
appropriate) using the join-key fields. 202
(4) OSA shall publish the report, management letter, and CAP 203
on Transparency Mississippi and transmit them to the Legislative 204
Budge Office (LBO). The report shall identify any payments that 205
appear to diverge from the auditee's stated purposes or the 206
statutory/contractual basis for receiving public funds. 207
(5) Reports are due within one hundred eighty (180) days 208
after fiscal year end of year OSA preforms or directs a compliance 209
audit, and OSA shall retain these report records for no less than 210
seven (7) years. 211
(6) Failure to submit, material noncooperation, or 212
obstruction authorizes DFA to suspend payments, withhold new 213
awards or recoup funds, and authorizes OSA to refer the matter to 214
the Attorney General. 215
(7) The auditee's schedules and CAP shall be certified under 216
penalty of perjury by an authorized officer and certified public 217
accountant. 218
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ST: MS Grant and Subgrant Administration
Transparency and Accountability of Non-
Governmental Organizations Act; create.
SECTION 6. This act shall take effect and be in force from 219
and after July 1, 2026. 220