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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.

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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.
  • Institution receiving prime award has a responsibility to monitor activities of subrecipients.

OPAA 6/09

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Subrecipient Monitoring
  • Agreements are Known as:
    • Subawards
    • Subcontracts
    • Subgrants
    • Subrecipients

OPAA 6/09

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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

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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