1 / 16

Subrecipient Monitoring

Subrecipient Monitoring. OMB Circular A-133 requires that subrecipients comply with federal audit requirements. Subrecipients must also comply with OMB Circulars A-21 and A-110 for cost principles and uniform administrative requirements.

annot
Télécharger la présentation

Subrecipient Monitoring

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. Subrecipient Monitoring • OMB Circular A-133 requires that subrecipients comply with federal audit requirements. • Subrecipients must also comply with OMB Circulars A-21 and A-110 for cost principles and uniform administrative requirements. • Institution receiving prime award has a responsibility to monitor activities of subrecipients. OPAA 6/09

  2. Subrecipient Monitoring • Agreements are Known as: • Subawards • Subcontracts • Subgrants • Subrecipients OPAA 6/09

  3. Subrecipient Monitoring What is a Subagreement? • An agreement that is written under the authority of and consistent with, the terms and conditions of a prime award and authorizes a portion of the research or substantive effort to be performed by another organization.. OPAA 6/09

  4. Subrecipient Monitoring Has programmatic responsibilities Performance is measured against the project objectives or scope of work. • The Subrecipient functions as a co-investigator on the project. OPAA 6/09

  5. Subrecipient Monitoring • Subrecipient Agreements: • Sponsor prior approval is required. • Subrecipients should be identified in the proposal. • Scope of work to be completed should be included. • Subrecipient costs should be included in the proposal budget. OPAA 6/09

  6. Subrecipient Monitoring • Subrecipient Agreements: • All terms and conditions of the prime award are included in the subaward. • Program compliance requirements are passed down to subrecipient. • Terms to include: • Financial and technical reporting requirements. • Any required cost share. OPAA 6/09

  7. Subrecipient Monitoring • Subagreements: • Terms to include: • Payment terms. • Audit clauses. • Record retention requirements • Access to records. • Agreements are prepared by Sponsored Programs Office. • Signature of acceptance of these terms by the receiving entity is required. OPAA 6/09

  8. Subrecipient Monitoring • Prime Institution Responsibilities Include: • Write the subaward, including scope of work. Attach a copy of the prime award. • Communicate with key personnel listed in subaward. • Ensure all reporting obligations are met. • Verify that subaward scope of work has been completed. • Monitor for compliance with award terms and conditions and federal requirements. OPAA 6/09

  9. Subrecipient Monitoring • PI / Dept / Business Center Monitoring Procedures: • Review budget line item detail of invoices for compliance with regulations. • Is amount requested within contract amount? • Are the invoice dates within time period of award? • Verify with Principal Investigator that sufficient progress is being made. OPAA 6/09

  10. Subrecipient Monitoring • OPAA Monitoring Procedures: • Request annual audit report. • Facilitate closing of the subaward. • Before the final invoice is paid: • Collect financial and technical reports • Collect cost share and equipment reports, if needed. • Obtain subrecipient release documents. • Assure compliance with all terms of the award OPAA 6/09

  11. Subrecipient Monitoring • Subrecipient Responsibilities include: • Compliance with award terms and conditions; OMB circulars A-110, A-21 and A-133. • Obtain independent audit. • Submit results of A-133 audit to prime institution. Any audit findings affecting award must be disclosed. • Submit invoices to prime recipient, including budget line item detail. OPAA 6/09

  12. Subrecipient Monitoring • Subrecipient Responsibilities include: • Communicate with prime recipient Principal Investigator. • Ensure all financial and technical reporting requirements are met. • Comply with record retention requirements. • Maintain financial systems and accurate records identifying project expenses. OPAA 6/09

  13. Subrecipient Monitoring • Special Considerations: • Foreign, industry, commercial, and non profit organizations are not subject to the OMB circular costing, uniform administrative or audit requirements. • Individual monitoring plans must be developed. • Make sure the organization agrees to the monitoring plan. OPAA 6/09

  14. Subrecipient Monitoring • Remember: • The legal relationship is between the prime recipient and the subrecipient. • All communications from the subrecipient must be to the prime recipient and not directly with the sponsoring agency. • There must be a statement of work concise as to what, when, and how the subrecipient tasks will be accomplished. OPAA 6/09

  15. Subrecipient Monitoring • Remember: • Flow down correct regulations. • Grants and Cooperative agreements – flow down OMB Circulars. • Contracts – flow down FAR clauses. • Contact the Office of Post Award Administration if there are any issues regarding this Subagreement, including issues of non-payment. OPAA 6/09

  16. Subrecipient Monitoring • Remember: • Sanctions and penalties applied to the prime recipient when subawardee fails to comply: • Non performance • Violating regulations • Mismanagement of award You are responsible for the actions of your subrecipients! OPAA 6/09

More Related