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Subrecipient Monitoring

Learn about the HMS Subrecipient Monitoring Committee and its role in ensuring compliance with federal regulations. |

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Subrecipient Monitoring

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  1. Subrecipient Monitoring This Photo by Unknown Author is licensed under CC BY-NC-SA Presented by the HMS Subrecipient Monitoring Committee 04/11/2018

  2. Membership/Structure • Founded in April 2014 • Current Members: • Chair: Melissa Maher, Manager, Subawards, HMS Office of Research Administration (ORA) • ORA: Susan Cohn-Child, Sivan Ehrlich • ORA Research Finance: Rita Bergemann, Mark O’Brien • Academic & Research Integrity: Suzanne Higgins, Samantha Speyer • Department: Monica Ruse, Steven Dawson, Sunny Alvear, John Serpico, Victoria Nguyen • https://hlcra.harvard.edu/hms-subrecipient-monitoring-committee

  3. Subaward Statistics • Harvard Schools with subagreements: How does HMS compare? As of January 2018:

  4. Why Subrecipient Monitoring? • Uniform Guidance: Requires prime recipients of federal funds (“pass-through entities”) to: • evaluate each subrecipient's risk of noncompliance in order to determine the appropriate monitoring level; • monitor the activities of subrecipients to ensure 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 UG • Non-federal subs: Monitoring of subs is still required by Harvard’s Subrecipient Monitoring policy, may be required by sponsor • ensure good stewardship of sponsored funding

  5. Risk Assessment Database: GMAS Transition • Each subrecipient organization is assessed annually - or every 3 years for Single Audit entities - by OSP and assigned a risk level of Green (low-risk), Yellow (medium-risk or insufficient data), or Red (high-risk) • The GMAS Organization page will now contain the risk assessment information that was available in the database, except for quarterly comments • Same permissions will apply – Assessors (OSP + “HEAT” Harvard extended assessment team) will have access to edit, while other GMAS users will have view access • Can also see current awards with a subrecipient institution across Harvard from the Organization page; ability to drill down into records dependent on your permissions

  6. Subs Process – Emails to Dept. • ORA’s process for drafting a new subaward or amendment includes sending an email to department to review for accuracy (correct dates, dollars, etc.) • We recently updated the email template we use (regular email and DocuSign) when sending drafts to departments for review, to clarify roles and responsibilities

  7. Subs Process – Emails to Dept.

  8. ORA Outgoing Subs Process • OSP and ORA are responsible for risk assessments and checking a subrecipient’s risk level when issuing and award • Departments can check risk assessments and comments in GMAS but are NOT required to do so • HLCRA Business Process Page for HMS (Outgoing Subawards Process): https://hlcra.harvard.edu/hms-ra-business-processes • Process is for ORA’s internal use, but shared to give others insight and information

  9. Updates to HLCRA • Harvard’s Subrecipient Monitoring Policy and Toolkit, and other university-wide and HMS resources can also be found on HLCRA (https://hlcra.harvard.edu/) • The HMS and SPH Subrecipient Monitoring Committees recently collaborated to update subaward-related content on HLCRA: • Subaward resources can now be found under Resources > Award Lifecycle > Proposal Development > Preparing a Proposal > Inclusion of Subawards. • Previous “Subaward FAQs” section has been deleted; this information is covered in other topic-specific pages. • Information relating to subrecipient monitoring can still be found under Resources > Award Lifecycle > Award Management. New tabs have been added which provide links to University-wide subrecipient monitoring policies and resources.

  10. Policy and Toolkit • Harvard’s Subrecipient Monitoring Policy and Toolkit are published on the OSP website and are also available on HLCRA. (https://hlcra.harvard.edu/) • Minor changes made recently to reflect transition of risk assessment database information into GMAS • Toolkit has been recently updated to include: • Changes to the Database User’s guide • Advance Payment Guidance • Minor language changes throughout the Toolkit

  11. OBI Quarterly Reports • Departments will remain responsible for completing quarterly spreadsheets • No change to process, but enhancements to OBI in process

  12. Contact Us Questions, Concerns, Suggestions? Contact the HMS SMC at: HMS_Submonitoring@hms.harvard.edu Thank you! This Photo by Unknown Author is licensed under CC BY-SA

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