Subrecipient Monitoring Policy

Title: Subrecipient Monitoring Policy
Policy Owner: Sponsored Program Services
Applies to: Faculty and Staff conducting sponsored program activity
Campus Applicability:  All Campuses except for UConn Health
Effective Date: June 18, 2015
For More Information, Contact Office of the Vice President for Research, Sponsored Program Services
Contact Information: (860) 486-3622
Official Website: http://research.uconn.edu

REASON FOR POLICY

To provide guidance to the University community in complying with the Office of Management and Budget (OMB) Uniform Guidance 2 CFR Part 200, subpart F and Circular A-133 (hereinafter, referred to as “Single Audit”), specifically with respect to its regulations regarding the oversight of subrecipients on federally sponsored programs.

APPLIES TO

This policy applies to faculty and staff at the Storrs and regional campuses who are working with subrecipients.  For federal awards/subawards issued with a start date before December 26, 2014, 2 CFR Part 215 and 220 (OMB Circulars A-21, A-110), and A-133 apply.  New funds (i.e., new awards, continuation funding, and supplements, etc.) received with a start date on or after December 26, 2014 are subject to the OMB Uniform Grant Guidance (2 CFR Part 200) unless specified otherwise in the terms and conditions of the award document.

Definitions

OMB Uniform Grant Guidance (2 CFR Part 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards): Consolidates and supersedes eight previous OMB Circulars (A-21, A-50, A-87, A-89, A-102, A-110, A-122 and A-133), which specifies grant management and audit responsibilities. Single audit regulations also describe the prime recipient/awardee’s responsibility for monitoring subrecipients.

OMB Circular A-133: The circular that specifies federal and recipient audit responsibilities; it also describes recipient’s responsibilities for monitoring subrecipients.

Prime Agency/Sponsor: The agency providing funds directly to the University.

Prime Recipient/Awardee: The institution or non-Federal awardee that receives an award directly from the sponsor.

Subrecipient: The legal entity to which a subaward is made and is accountable to the prime recipient for the use of the funds provided.  Subrecipients must adhere to the terms and conditions of the prime award passed down to the subrecipient organization in the subaward agreement (subrecipient may also be referred to as subawardee, subgrantee, or subcontractor).

Prime Award: Funds obligated by a Sponsor/funding agency to the University for a specific project.

Subaward: An agreement entered into by the University with another entity (i.e., the subrecipient).  The University agrees provide funds to the entity to conduct a portion of the work specified in the statement of work (SOW) submitted as part of the proposal.

Kuali Financial System (KFS): The University of Connecticut at Storrs and regional campuses financial system of record.

Catalog of Federal Domestic Assistance (CFDA) Number: A unique five digit number assigned to each federally funded assistance program.  The first two digits identify the agency and the last three digits identify the program.

Principal Investigator (PI): Individual responsible for the development, writing, and conduct of a sponsored award, including primary responsibility for the technical and fiscal management of the award.

POLICY STATEMENT

It is the responsibility of the University to ensure our subcontractors meet the terms, conditions, as well as the regulations by sponsors from which funds are received.  As a condition of accepting funding from a sponsor, the University is obligated in its role as primary recipient to undertake stewardship activities as well as comply with federal and state laws, sponsor requirements and University policy.  When the University assigns responsibility for conducting a portion of the work to a subrecipient, the University remains responsible to the sponsor for the management of funds and meeting project performance goals.  Thus, the monitoring of technical and financial activities associated with a subrecipient is an integral part of the University’s stewardship of sponsored funds

The University will assess the subrecipient organization’s financial and internal controls and may include additional terms and conditions in the subrecipient agreement consistent with the level of risk identified.

Note: A significant financial interest held by the PI in the subrecipient entity must be disclosed to the Conflict of Interest Office.

The University will perform the following stewardship activities with regard to subrecipients:

  • Advise subrecipients of requirements, including but not limited to financial and non-financial reporting, imposed on them by federal laws, regulations of the flow-down provisions of the prime award and any supplemental requirements imposed by the University dependent on level of risk as determined by the University;
  • The University shall provide the best information available to describe a federal award to each subrecipient including the CFDA number, prime award number, award year, and the name of the sponsor as required by OMB Uniform Grant Guidance or Circular A-133;
  • Require each subrecipient to permit the sponsor and/or the University and its auditors to have access to the pertinent records and financial statements, as necessary;
  • Monitor expenditures and activities of the subaward to confirm that funding provided to the subrecipient is used for purposes authorized in the agreement and that performance goals articulated in the statement of work are achieved.  As part of this activity, PIs are required to sign invoices authorizing payments to subrecipients.  This requirement cannot be delegated;
  • Confirm subrecipients expending $500,000 (before 12/26/2014) or $750,000 (on or after 12/26/2014) or more in federal awards during the subrecipient’s fiscal year are compliant with OMB Circular A-133 or Uniform Grant Guidance audit requirements by requesting audit confirmation from all subrecipients. The subrecipient is to certify whether findings were or were not reported as part of their audit;
    • Upon receipt of a subrecipient audit report that include findings:
      • the University will review and determine whether funds are required to be returned to UConn or any financial adjustments necessary as a result of the audit’s disclosed findings;
      • the University will confirm that the subrecipient has taken appropriate and timely corrective action;
      • the University will issue a management decision letter to the subrecipient as required by regulation.

If a material weakness or other reportable condition exists, management actions, including termination of the agreement, may be taken as appropriate.

ROLES AND RESPONSIBILITIES

Principal Investigator

  1. Obtains proposal-relevant documentation from subrecipient, including Subrecipient Checklist and Consortium Statement, and submits with proposal for review and approval to the Office of the Vice President, Sponsored Program Services (OVPR SPS).
  2. Monitors the technical progress of a subrecipient’s performance as defined in the subaward.
  3. Ensures that subrecipient has met all deliverables.
  4. Ensures that subrecipient has complied with all applicable public policy requirements and objectives.
  5. Reviews invoices for cost allowability, compliance with federal regulations, prime award and subaward terms and conditions.  In addition, ensures that the amount billed is consistent with technical/progress reports and production of deliverables.
  6. Approves invoices for payment via KFS. This task may not be delegated.
  7. Submits invoices for payment in a timely manner and retain copies for departmental records.
  8. Notifies OVPR SPS when problems arise regarding invoicing or performance.

Department Grant Administrator

  1. Assists PIs in meeting their monitoring responsibilities, as specified above.

OVPR SPS

  1. Initiates Pre-qualification subrecipient reviews; consults with the appropriate University departments as necessary to perform subrecipient risk assessment for first-time subrecipients.
  2. Negotiates and executes subaward agreements between the University and subrecipient organizations, including appropriate language requiring adherence to federal regulations and other sponsor requirements as applicable.
  3. Provides special terms and conditions in the subaward to manage risk.
  4. Issues and collects annual single audit certification letters and Subrecipient Profile Questionnaire for non-A-133 subrecipients.  Issues management decision on subrecipient audit findings.
  5. Documents annual compliance certifications.
  6. Performs a final review of costs charged and facilitates close-out of all commitments.
  7. Assists to resolve financial questions related to invoices.
  8. Ensures that the University’s subrecipient monitoring procedures are compliant with Federal, non-Federal, and other applicable regulations.
  9. Provides training and guidance in interpreting regulations, subaward terms and conditions and executing these guidelines and requirements.

ENFORCEMENT

Violations of this policy may result in appropriate disciplinary measures in accordance with University Laws and By-Laws, General Rules of Conduct for All University Employees, applicable collective bargaining agreements, and the University of Connecticut Student Code.

PROCEDURE/ FORMS

Related procedures and guidance are available on the OVPR SPS website under the heading of Subawards.

POLICY HISTORY

Policy created3/22/2013

Revised:            6/18/2015 (Approved by the Vice President for Research)