Subrecipient Monitoring – 603.15

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University of Arkansas at Little Rock
Policy Name: Subrecipient Monitoring
Policy Number: 603.15
Effective Date: June 27, 2016

Policy

The UALR Office of Research and Sponsored Programs must monitor the programmatic and financial activities of all subrecipients of sponsored funds that have been primarily awarded to UALR. The university may impose specific controls, as needed, for certain subrecipients based on relevant risk factors. The terms of the subrecipient’s relationship with the university are documented in a written subaward agreement between the university and the subrecipient organization.

Purpose

OMB Uniform Guidance 2 CFR §200.331 requires pass-through entities to evaluate each subrecipient’s risk of noncompliance in order to determine the appropriate monitoring level, monitor the activities of subrecipient organizations to ensure that the subaward is in compliance with applicable Federal statutes and regulations and terms of the subaward, and verify that subrecipients are audited as required by Subpart F of the Uniform Guidance. The university must ensure that sponsor funds are properly spent, that performance goals are met, and that subrecipients comply with all applicable law, regulations, and prime award terms.

To Whom Does This Policy Apply

All UALR personnel involved with the administration and conduct of sponsored awards that issue and manage subawards must comply with this policy.

Roles and Responsibilities

Subrecipient monitoring responsibilities are shared among the following:

PI & Department

  • Assess potential subrecipient organizations for programmatic, financial, and administrative suitability at the time of proposal.
  • Request subrecipient organization information at the proposal stage.
  • Confirm the statement of work and review any non-standard terms and conditions of the subaward during the subaward agreement negotiation process.
  • Monitor program progress and subrecipient’s ability to meet subaward objectives.
  • Monitor subawards and maintain written documentation throughout the performance period and send any concerns to ORSP.
  • Provide records of subaward monitoring of individual subawards for ORSP as requested.
  • Work with ORSP to resolve issues on subawards as they arise.

ORSP

  • Gather information on new subrecipient organizations and review existing subrecipient organizations on an annual basis.
  • Inform the relevant UALR PIs when issues are identified with a subrecipient organization.
  • Review information obtained for initial subrecipient organization risk assessment and assign a risk rating.
  • Incorporate additional terms into subawards based on information from the PI, department, and the risk assessment of the subrecipient organization.
  • Review, revise, and approve risk assessments on new subrecipient organizations and annual updates to subrecipient organizations’ risk ratings.
  • Review problematic subawards.
  • Update subrecipient organization risk rating when appropriate.

Vice Chancellor for Finance Office and Office of the Provost

Review and approve certain high-risk projects that may involve subrecipients at the proposal stage and, as necessary, during the life of the award.

Procedures

Reviewing and assessing subrecipient organizations

All new and existing active subrecipient organizations will be rated annually. ORSP will obtain copies of the Single Audit Reports if the entity is subject to 2 CFR 200, Subpart F, or request financial and other relevant information for institutions not subject to the Single Audit requirements. A risk rating will be assigned prior to issuing a subaward.

Including subawards in a proposal

Before including a subaward in a proposal, PIs should consider the ability of the subrecipient organization to perform the work and adequately manage the administrative and financial responsibilities outlined in the subaward terms and conditions.

Drafting and negotiating a subaward 

If a subaward is deemed appropriate, all applicable terms and conditions of the prime award must be flowed down to the subrecipient organization. When drafting the subaward agreement, ORSP will review the risk assessment and rating level, any prior UALR experience with the subrecipient, and any other available information to determine if additional terms and conditions should be included in the subaward agreement.

Ongoing monitoring of individual subawards

Ongoing programmatic and financial review of each subaward is required by the PIs on a consistent basis.  Written documentation of the monitoring and results must be maintained by the PI. Material issues with subawards should be escalated to ORSP.

Escalation and resolution of problematic subawards

PIs and department/local unit staff should report issues to ORSP. ORSP may change the risk rating, recommend additional monitoring, revise terms and conditions of the subaward agreement, and/or other procedures to remedy the concern.


Source: Office of Research and Sponsored Programs
Revised:
Approved By: Chancellor Joel E. Anderson, June 27, 2016
Custodian: Office of Research and Sponsored Programs