10.12 - Subrecipient Monitoring Policy

Making of Subawards

The University may make subawards of federal funds to other organizations. All subrecipients must agree to the subrecipient monitoring provisions described in the next section.

An appropriate level of pre-award inquiry that shall be performed. The purpose of such inquiry, which may involve a site visit to a potential subrecipient, is to gain assurance that a potential subrecipient has adequate policies and procedures in place to provide reasonable assurance that it is capable complying with all applicable laws, regulations, and award provisions.

Elements of Subaward

The University will ensure that every subaward is clearly identified to the subrecipient as a subaward and include the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modifications. When some of this information is not available, the University will provide the best information to describe the Federal award and subaward.

Subaward agreements shall include all information necessary to identify the funds as federal funding. This information shall include:

1. Subrecipient name (which must match registered name for Unique Entity Identifier).
2. Subrecipient's Unique Entity Identifier.
3. Federal Award Identification Number (FAIN).
4. Federal Award Date.
5. Subaward Period of Performance Start and End Date.
6. Amount of Federal Funds Obligated by this action.

1. Total Amount of Federal Funds Obligated to the subrecipient.
2. Total Amount of the Federal Award.
3. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA).
4. Name of Federal awarding agency, pass-through entity, and contact information
5. Assistance Listing Number and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listing number at time of disbursement.
6. Identification of whether the award is R&D; and
7. Indirect cost rate for the Federal award (including if the de minimis rate is charged)

Subaward agreements shall identify all applicable audit requirements, including the requirement to obtain an audit in accordance with 2 CFR Part 200 Subpart F, if the subrecipient meets the criteria for having to undergo such an audit.

Subawards shall include a listing of all applicable Federal requirements that each subrecipient must follow.

Subawards shall require that subrecipients submit financial and program reports to the University on a basis described in the subaward agreement.

Subawards shall require that subrecipients permit the University and auditors access to the subrecipient’s records and financial statements, as necessary.

Risk Assessment

The University will evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring, which may include consideration of such factors as:

1. The subrecipient’s prior experience with the same or similar subawards.
2. The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with 2 CFR Part 200 Subpart F, and the extent to which the same or similar subaward has been audited as a major program.
3. Whether the subrecipient has new personnel or new or substantially changed systems.
4. The extent and results of Federal awarding agency monitoring (i.e., if the subrecipient also receives Federal awards directly from a Federal awarding agency).

    

   Monitoring of Subrecipients

   When the University utilizes Federal funds to make subawards to subrecipients, the University is subject to a requirement to monitor each subrecipient in order to provide reasonable assurance that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. In fulfillment of its obligation to monitor subrecipients, the following policies apply to all subawards of Federal funds made by the University to subrecipients:

    

1. The University will review programmatic and financial reports prepared and submitted by the subrecipient and following up on areas of concern.
2. The University will follow up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from The University detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward.
3. The University will issue a management decision for audit findings pertaining to the subaward as required by 2 CFR Part §200.521. The University will consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. The University is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings.
4. Ongoing monitoring of subrecipients by the University will inherently vary from subrecipient to subrecipient, based on the nature of work assigned to each subrecipient. Depending upon The University’s assessment of risk posed by the subrecipient, the following monitoring tools may involve any or all of the following:
   1. Regular contacts with subrecipients and appropriate inquiries regarding the program.
   2. Monitoring subrecipient budgets.
   3. Performing site visits to the subrecipient to review program operations, financial and programmatic records and assess compliance with applicable laws, regulations, and provisions of the subaward.
   4. Providing subrecipients with training and technical assistance on program-related matters.
   5. Establishing and maintaining a tracking system to assure timely submission of all reports required of the subrecipient.

1. Documentation shall be maintained in support of all efforts associated with the University’s monitoring of subrecipients.

Subrecipient Noncompliance

In connection with any subrecipient that has been found to be out of compliance with provisions of its subaward, responsive actions shall be determined. Such actions may consist of any of the following actions:

1. Increasing the level of supporting documentation that the subrecipient is required to submit on a monthly or periodic basis.
2. Requiring that subrecipient prepare a formal corrective action plan for submission.
3. Requiring that certain employees of the subrecipient undergo training in areas identified as needing improvement.
4. Requiring documentation of changes made to policies or forms used in administering the subaward.
5. Arranging for on-site (at the subrecipient’s office) oversight on a periodic basis by a member of the fiscal or grant administration staff.
6. Providing copies of pertinent laws, regulations, federal agency guidelines, or other documents that may help the subrecipient.
7. Arranging with an outside party for periodic on-site monitoring visits.
8. Reimbursing after-the-fact, and not provide advances.
9. Requiring review and approval for each disbursement and all out-of-area travel.