Monitoring Sub-Recipients

Op4.02-12 Monitoring Sub-Recipients

Introduction

The University issues Subawards to Subrecipients to augment the University’s core capabilities. Administration of these Subawards is specifically addressed in Office of Management and Budget (OMB) 2 CFR 200 titled Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Specific monitoring requirements of the Subrecipients are contained in Subpart D of the Uniform Guidance and the accompanying Compliance Supplement.

Policy

This policy covers Missouri State University’s (University) responsibility for financial and programmatic monitoring of federally sponsored project funds awarded to the University that are subcontracted to another institution or organization (Subrecipient).

Subrecipient monitoring starts with the preparation and issuance of the Subaward document, continues through the execution of the Subaward and ends after all conditions of the Subaward have been met and the Subaward is closed.

Before Executing Subawards

The Office of Research Administration (ORA) will perform and document an Excluded Parties List System (EPLS) check to ensure the potential Subrecipient is not suspended or debarred.

The ORA will perform a review and risk assessment for all Subrecipients that are federally funded (which includes direct and flow-through awards).

If there is a high level of risk associated with the Subrecipient, ORA, in consultation with Grants & Contract Accounting (GCA), will ensure the appropriate risk mitigation steps are taken and the necessary language is included in the Subaward.

Post Award Subrecipient Monitoring

Principal Investigators (PIs) are responsible for monitoring periodic progress reports to ensure that performance goals are achieved. PIs and GCA are responsible for monitoring invoices to ensure that they are reflective of progress and, to the extent possible, that the Subrecipient is administering the Federal awards in compliance with laws, regulations, and the provisions of the subcontract agreements. Non-compliance with technical reporting requirements or dissatisfaction with the level of Subrecipient progress should be reported immediately to ORA and GCA.

Annual Subrecipient Monitoring

On an annual basis, GCA will obtain copies of the Subrecipient’s single audit report from the Federal Audit Clearinghouse or directly from the Subrecipient and, if required, an audit certification for all active Subrecipients receiving federal funding during the prior fiscal year. Upon receipt of an audit report with findings related to funding provided by the University or material findings related to the Subrecipient’s internal controls, GCA will issue a management decision and follow-up to ensure the appropriate corrective actions have been taken by the Subrecipient.

At the time the annual review, GCA will perform and document an EPLS check to ensure the Subrecipient is not suspended or debarred.