X. Subrecipient Monitoring
The policy also outlines the responsibilities of the Principal
Investigator in assuring both programmatic and fiscal compliance of
subrecipients to the terms and conditions established by the
sponsoring agency.
PURPOSE
This policy seeks to:
- promote stewardship of funds used to pay subrecipient
organizations;
- promote appropriate responsibility and accountability for
contractual subrecipient relationships;
- promote compliance with federal, state, University, and other
legal requirements related to subrecipient monitoring; and
- ensure that the University and its sponsors receive value for
funds expended.
As required by OMB Circular A-133, all subawards issued by the
University shall provide the best information available to describe
the award, including:
- Catalog of Federal Domestic Assistance (CFDA) title and
number
- Award name and number
- Name of federal agency
The University is obligated to advise subrecipients of
requirements that are imposed on them by federal laws, regulations,
and the provisions of the sponsored project award document.
ubrecipients are required to permit the University and its auditors
to have access to records and financial statements pertaining to
the subaward.
Except in unusual cases, subrecipients must be identified in the
proposal submitted to the sponsoring agency. Following the
execution of subawards, the University is required to monitor the
subrecipient's activities to ensure that activities are conducted
in compliance with regulations and that performance goals are
achieved. In general, when a significant percentage of an award is
passed through the University to a subrecipient, more intense
monitoring is necessary. Regular communication with the
subrecipient is required.
The University shall monitor subrecipients to ensure compliance
with audit requirements. If audit findings are revealed, the
University shall issue a management decision within sixty days
following the receipt of the subrecipient's audit report and
confirm that the subrecipient has taken appropriate corrective
actions in a timely manner. If the subrecipient's corrective action
plan is not submitted to the University within thirty days, the
subrecipient will receive a follow-up phone call or email from the
school's budget officer, or the OGSP grants officer. If the
corrective action plan is not received by the end of sixty days, a
letter will be sent from the Associate Provost. After ninety days,
a letter will be sent from University Counsel to inform the
subrecipient that failure to respond may result in the termination
of the subaward.
If the subrecipient's audit findings necessitate adjustments in
the University's financial records, such adjustments shall be made
in a timely manner.
A-133 CERTIFICATIONS
- Non-profit subrecipients who expended $500,000 or more in
federal funds during the previous fiscal year are required to have
an A-133 audit on an annual basis or may elect to have a
program-specific audit. OGSP shall request annual A-133
certifications from all subrecipients. This certification requires
that subrecipients certify that their A-133 audits revealed no
questionable findings or provide a detailed disclosure of
findings.
- Subrecipients who are not subject to A-133 audit requirements
shall complete a financial disclosure and shall be required to
submit in a program specific audit, performed by an independent
external entity, upon request by the University.
- If audit findings are revealed, OGSP shall issue a management
decision within sixty days of notification and shall provide
additional monitoring to ensure that timely and appropriate
corrective actions are taken in response to audit findings.
- Internal Audit shall provide assistance with issuing management
decisions and ensuring that appropriate corrective actions are
taken.
SUBAWARD CHANGES
- Subrecipients are required to notify the University and obtain
prior written approval from their school's budget officer or the
OGSP grants officer for any changes that may materially alter the
terms of the subaward. Examples include, but are not limited to,
changes in the period of performance, scope of work, or
budget.
- The Principal Investigator shall work with the subrecipient to
ensure that any changes that may materially alter the terms of the
subaward are immediately reported to OGSP for approval or the
school's budget officer.
- OGSP and/or the school's budget officer shall provide approval
in a timely manner; in most cases, a formal subaward amendment will
be required.
THIRD-TIER SUBCONTRACTERS
- When subrecipient budgets include funds for contractual
purposes, the Principal Investigator shall work with the
subrecipient to facilitate the timely provision of required
documentation to OGSP and/or the budget officer.
- OGSP and/or the school's budget officer shall review third-tier
subcontracters included in subaward budgets, request identification
of the entity by name, request justification for how the entity was
selected (i.e., evidence of competitive bid process or sole source
justification), and provide the subrecipient with written approval
prior to the subrecipient entering into a contractual relationship
with a third-tier subcontractor.
- OGSP and/or the school's budget officer shall request any
additional documentation from the subrecipient needed to make an
informed decision about the approval of third-tier
subcontractors.
CONTRACT REVIEW
The Office of University Counsel shall review all subawards with
variations from the approved subaward template. University Counsel
shall work with the Principal Investigator and OGSP and/or the
school's budget officer to negotiate changes to proposed subawards
prior to their execution.
COMMUNICATION WITH SUBRECIPIENT
The Principal Investigator shall maintain sufficient contact
with the subrecipient to assess accurately whether the subrecipient
is adequately performing the statement of work and reasonably
progressing towards the achievement of the performing goals.
REVIEW OF TECHNICAL PERFORMANCE REPORTS
The Principal Investigator shall obtain periodic written
performance reports from the subrecipient. uch reports should
generally contain a comparison of actual accomplishments with the
goals and objectives established for the period.
REVIEW OF FINANCIAL INVOICES
- Upon receipt of financial invoices, the Principal Investigator
shall review and assess whether the charges on the invoice
reasonably match progress made on the project. If an invoice is
believed to be inaccurate, Principal Investigators shall contact
the subrecipient for clarification and request additional
documentation before forwarding the invoice to Grant Accounting for
payment.
- Prior to approving and issuing payments on subawards, a
financial officer shall review financial invoices for compliance
with sponsor guidelines and the terms of the subaward.
- A financial officer shall work with the Principal Investigator
and subrecipient to secure any additional documentation needed to
process invoice payments and shall withhold payment on invoices
until such documentation is received.
SITE VISITS
Depending on the scope of the work and level of involvement from
the subrecipient, site visits are often necessary to ensure an
effective collaboration. The Principal Investigator shall arrange
and maintain documentation for such visits.
FINANCIAL DISCLOSURE STATEMENTS