SubRecipient Monitoring: From Preparation to Closeout

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Sub-Recipient MonitoringFrom Preparation to
Closeout
Andrea Comley, CRAContract Review Officer
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Todays Objectives

• Identify the requirements of monitoring.
• Provide example of one monitoring program.
• Discuss how to implement monitoring programs.

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First Some Definitions

• Subaward - an award of financial assistance in
  the form of money, or property in lieu of money,
  made under an award by a recipient to an eligible
  subrecipient or by a subrecipient to a lower tier
  subrecipient. The term includes financial
  assistance when provided by any legal agreement,
  even if the agreement is called a contract, but
  does not include procurement of goods and
  services (OMB Circular A-110 Subpart A, Section
  2)
• Subrecipient - a non-Federal entity that
  expends Federal awards received from a
  pass-through entity to carry out a Federal
  program, but does not include an individual that
  is a beneficiary of such a program. A
  subrecipient may also be a recipient of other
  Federal awards directly from a Federal awarding
  agency. (OMB Circular A-133 Subpart A -
  Definitions)

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Requirements

• OMB Circular A-133 and the Compliance Supplement
  provide the requirements for monitoring
  Sub-recipients
• Recipients are responsible for managing and
  monitoring each project, program, subaward,
  function or activity supported by the award.
  Recipients shall monitor subawards to ensure
  subrecipients have met the audit requirements as
  set forth in 74.26. (45 CFR Part 74 Subpart C
  Post Award Requirements, Section 51)

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Requirements

• Award Identification
• During-the-Award Monitoring
• Sub-recipient Audits
• Pass-Through Entity Impact

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Requirements

• Award Identification
• Identify Federal award information on the
  sub-award along with compliance requirements.
• CFDA title number
• Award Name
• Name of Federal agency

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Requirements

• During-the-Award Monitoring
• Monitor sub-recipient use of Federal awards
  through reporting, site visits, regular contact
  or other means to reasonably assure that the
  sub-recipient is complying with federal
  regulations, laws, terms and conditions and that
  performance goals are achieved.

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Requirements

• During-the-Award Monitoring
• Items that may affect the nature, timing and
  extent of monitoring
• Program Complexity
• Percentage Passed Through
• Amount of Award
• Sub-recipient Risk

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Requirements

• During-the-Award Monitoring
• Types of Monitoring
• Reporting
• Site Visits
• Communication

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What Auditors Look For in Sub-Recipient
Monitoring Programs

• Established Monitoring Program
• Proper identification of Federal pass-through
  information on award documents
• Monitoring that ensures compliance by
  Sub-recipient
• Follow-through on Sub-recipient audits and
  findings
• Appropriate action in non-compliance situations.

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How to Ensure Your Program is Working

• Check internal controls
• Test internal controls
• Based upon test results, determine how (nature,
  timing and extent) to re-check your monitoring
  program

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The Process of Sub-Recipient Monitoring
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In The Beginning

• Starts with the proposal
• Clearly defined Scope of Work and Performance
  Measures.
• Well prepared budget
• Identification of Sub-recipient contacts
• Commitment of Support and potentially Cost Share

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Then Came

The Sub-Award Obtain necessary data Subject
to A-133 Y or N Risk Level Scope of
Work Budget Reporting Requirements
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Sub-Award Request Form - Example
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Attachment 5 Budget
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Attachment 5 Budget - Match
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Now

• Preparing the Sub-Award
• Determine Risk
• Based upon risk, include appropriate Terms
  Conditions (TC) compliance requirements
• - additional detail required for invoicing
• - increased financial monitoring (invoice
  desk audits)
• - increased technical monitoring

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Keeping the Department/PI in the Loop

• Provide copy of Sub-Award to those charged with
  managing and monitoring the Sub-Award (PI,
  Department, Post-Award, etc.)
• Clearly communicate roles and responsibilities to
  ensure proper monitoring.

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• Notifying the Department/PI - Example

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Financial Technical Monitoring - Procedures

• Review of Performance
• Review of Technical Financial Reports
• Audits

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Financial Technical Monitoring

• Whos Who
• When developing processes, determine who holds
  responsibilities at which level.
• NOTE An individual with knowledge of the
  project and the performance requirements needs to
  approve the financial and technical reporting for
  acceptability (ie your PI).

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Financial Technical Monitoring

• Performance Technical Reporting
• PI responsible for monitoring performance.
• PI and Department responsible for monitoring
  receipt of technical reports.
• Advise Sponsored Programs Office if reporting
  requirements are not being met.

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Financial Technical Monitoring

• Financial Reporting
• PI and Departmental Review of Invoices, Cost
  Share, Final Financials
• Sponsored Program Review of Invoices, Cost Share,
  Final Financials (dependent on level of training
  at institution)
• Audit Review dependent upon TC and institution
  procedures

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Financial Technical Monitoring

• Audit
• Typically handled by Sponsored Programs Offices.
• Involve Department/PI and others as needed.

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Audit Procedures - Example
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Audit Follow-Through

• Send initial letter
• If no response to Audit requests 2nd notice
  then termination or other sanctions
• If audit not complete, calendar the date and
  follow-up
• If findings, ensure appropriate and timely
  corrective action is taken
• Termination or other sanction (withholding
  payment, etc) if Sub-recipient unwilling to comply

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Audit Follow-Through

• Invoice Desk Audits
• Completed by Sponsored Programs or Audit
  personnel.
• Requires coordinated input between PI,
  Department, Sponsored Programs and Audit
  personnel.

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Changes to the Sub-Award
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Changes to the Sub-Award

• Ensure there is clarity within your institution
  about how changes are handled
• Educate about prior approval requirements
• Document Changes
• Modify agreement as required
• Check in with your PI periodically

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• Sub-Award Amendment Request - Example

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Close-out

• Whos Who
• Involves PI, Department, Sponsored Programs and
  those performing audit functions for Sub-Awards.
• All must be in order (reports, commitments,
  technical data and deliverables) and received
  prior to close-out.

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Implementing Sub-Award Procedures

• Identify why the change for UI Audit findings
• How will the change impact your customers (PIs,
  Administrators, other central offices, etc)
• Identify benefits to customers (buy-in)
• Develop new procedures/policies
• Create Beta test group
• Finalize based upon input
• Education/Training
• Implementation

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Questions
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Andrea Comley, CRAContract Review
OfficerUniversity of IdahoOffice of Sponsored
Programsacomley_at_uidaho.edu(208) 885-6341