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Subrecipient Monitoring Procedure

Subrecipient Monitoring Roles and Responsibilities 

Please see flowchart for easy reference click here 

Reason

Subpart D of the Uniform Guidance (UG) (see § 200.330 through § 200.332) stated the Subrecipient monitoring and management. Specifically stated in §200.331 of the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) (“Uniform Guidance”), pass-through entities (PTE) are required to evaluate each subrecipient's risk of noncompliance in order to determine the appropriate monitoring level, monitor the activities of subrecipient organizations and to ensure that the subaward is in 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 Uniform Guidance.

Statement

In ensuring proper stewardship of sponsor funds, Chicago State University, is responsible for monitoring the programmatic and financial activities of its subrecipients. It is our institutional responsibility to assists Principal Investigators (PIs), administrators, faculty and staff who are working with subrecipients to ensure that in achieving performance goals of the sponsored project/s, that subrecipients comply with applicable federal laws and regulations and with the provisions of each subaward agreement.

Definitions

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Requirements, Cost Principles, and Audit Requirements for Federal Awards (aka Uniform Grant Guidance) Consolidated and superseded the eight previous Office of management and Budget (OMB) Circulars (A-21, A-50, A-87, A-89, A-102, A-110, A-122 and A-133), that specifies grant management and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

Single Audit – (formerly A-133) Subpart F of the OMB Uniform Guidance, is a rigorous, organization-wide audit or examination of an entity that expends $750,000 or more of federal assistance (commonly known as federal funds, federal grants, or federal awards) received for its operations.

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.

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

Subrecipient:The legal entity to which a subaward is made and is accountable to the prime recipient or Pass-thru-entity (PTE) 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). A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency.

Subaward: A form of legal agreement entered into by the University with another entity (i.e., the subrecipient).  The University agrees to 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.

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.

Federal Funding Accountability and Transparency Act (FFATA):  The Federal Funding Accountability and Transparency Act (FFATA or Transparency Act - P.L.109-282, as amended by section 6202(a) of P.L. 110-252) signed on September 26, 2006, requires the Office of Management and Budget (OMB)  to maintain a single, searchable website that contains information on all Federal spending awards.

The FFATA Subaward Reporting System is the reporting tool Federal prime awardees (i.e., prime contractors and prime grants recipients) use to capture and report subaward and executive compensation data regarding their first-tier subawards to meet the FFATA reporting requirements. Prime contract awardees will report against sub-contracts awarded and prime grant awardees will report against sub-grants awarded. The subaward information entered in FSRS will then be displayed on www.USASpending.gov associated with the prime award furthering Federal spending transparency.

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.

A Contractor (previously called vendor) is an entity that receives a contract as defined in § 200.22. Contract of the OMB Uniform Grant Guidance. Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal Award.  To assist in determining if a collaborator is a  Subrecipient  or a  Vendor, please click the form here.

Listed below are the characteristics of a subrecipient and a contractor as stated in UG Guidance § 200.330.

Characteristics of a Subrecipient

  • Determines who is eligible to receive what Federal assistance;
  • Has its performance measured in relation to whether objectives of a Federal program were met;
  • Is responsible for adherence to applicable Federal program requirements specified in the Federal award
  • Has responsibility for programmatic decision making
  • Uses Federal funds to carry out the program of the entity as compared to providing goods and services for a program of the pass-through entity 

Characteristics of a Contractor/Vendor

  • Provides the goods and services within normal business operations
  • Provides similar goods and services to many different purchasers
  • Normally operates in a competitive environment
  • Provides goods and services that are ancillary to the operations of the federal program
  • Is not subject to the compliance requirements of the federal program as a result of the agreement, though similar requirements may apply for other reasons

It is vital to properly distinguish between a subrecipient and a contractor particularly on the proposal stage of the budget as improper identification might affect the amount of award to be received, the computation of indirect cost, and the audit review of the grant. The Contractors, however, have the F & A – (commonly called Indirect Cost) basis, based on the total cost of goods and services.

 

SUBRECIPIENT MONITORING ROLES AND RESPONSIBILITIES

(Please see flowchart for easy reference) 

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 Grants and Research Administration (OGRA).
  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.
  7. Submits invoices for payment in a timely manner and retain copies for departmental records.
  8. Notifies OGRA when problems arise regarding invoicing or performance.

 

Office of Grants and Research Administration - OGRA

  1. Initiates Pre-qualification subrecipient reviews; Perform subrecipient risk assessment for each 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. Assists PIs in meeting their monitoring responsibilities, as specified above.
  6. Documents annual compliance certifications.
  7. Performs a final review of costs charged and facilitates close-out of all commitments.
  8. Assists to resolve financial questions related to invoices.
  9. Ensures that the University’s subrecipient monitoring procedures are compliant with Federal, non-Federal, and other applicable regulations.
  10. Provides training and guidance in interpreting regulations, subaward terms and conditions and executing these guidelines and requirements.

 

 

(Updated 04.02.2019)