Some grants require or permit the College to use the assistance of a subrecipient in completing the requirements and objectives of the project. In those cases, the College has created a formal sub-award agreement for all subrecipients to execute. Project Directors are responsible for working with the Sponsored Projects Office and the Office of Legal Affairs to create subaward agreements that contain all the necessary language as required by 2 C.F.R. 200.332 and the grant award.
Project Directors and their supervisors are also responsible for completing the subrecipient initial assessment and monitoring form. This form must be completed and sent to the Sponsored Projects Office for approval along with the post award subrecipient agreement. The SPO may consult with Office for Finance and Legal Services before approving.
Project Directors are responsible for monitoring the progress of their subrecipients. This is initiated by maintaining open lines of communication with the subrecipient. Subrecipients are invited to attend the Kick-off meeting with the Project Director and the Sponsored Projects Office.
|2 CFR § 200.332 – Requirements for pass-through entities|
|(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification. |
(i) Subrecipient name (which must match the name associated with its unique entity identifier);
(ii) Subrecipient’s unique entity identifier;
(iii) Federal Award Identification Number (FAIN);
(iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency;
(v) Subaward Period of Performance Start and End Date;
(vi) Subaward Budget Period Start and End Date;
(vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient;
(viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation;
(ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;
(x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA);
(xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity;
(xii) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement;
(xiii) Identification of whether the award is R&D; and
(xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414.
(2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award;
(3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports;
(i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either:
(A) The negotiated indirect cost rate between the pass-through entity and the subrecipient; which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so;
(B) The de minimis indirect cost rate.
(ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with § 200.405(d).
(5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and
(6) Appropriate terms and conditions concerning closeout of the subaward.
(b) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as:
(1) The subrecipient’s prior experience with the same or similar subawards;
(2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program;
(3) Whether the subrecipient has new personnel or new or substantially changed systems; and
(4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).
(c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208.
(d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include:
(1) Reviewing financial and performance reports required by the pass-through entity.
(2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward.
(3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the sub-recipient from the pass-through entity as required by § 200.521.
(4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient’s cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward.
(e) Depending upon the pass-through entity’s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals:
(1) Providing subrecipients with training and technical assistance on program-related matters; and
(2) Performing on-site reviews of the subrecipient’s program operations;
(3) Arranging for agreed-upon-procedures engagements as described in § 200.425.
(f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.
(g) Consider whether the results of the subrecipient’s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity’s own records.
(h) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations.
At the Kick-Off meeting, subrecipients are informed of:
- applicable federal laws and regulations
- all appropriate flow-down provisions from the grant agreement.
- Project Directors will provide the subrecipients with training and technical assistance on program-related matters and review all of the subrecipient’s program activities to ensure that deliverables and reporting requirements are met in a timely manner.
- On an annual basis, Project Directors are required to complete the Subrecipient Monitoring Form as a formal method of reviewing the subrecipient’s overall performance.
- The form contains criteria associated with evaluating the risk of a subrecipient. Responses are required in a yes/no format. A negative response requires a brief explanation in the “Comments” section.
- Upon completion of the form, Project Directors should assess whether further action is required in the form of a corrective action plan or audit.
- In addition to the subrecipient monitoring form, Project Directors must also perform on-site reviews of the subrecipient’s program operations.
- The frequency is determined by the nature of the project. However, the meetings must occur no less than annually.
- Invoices are required to be submitted on a monthly basis, as well.
- Project Directors must review invoices to ensure charges are reflective of work performed.
- Invoices are then forwarded to Office for Finance within 10 business days.
- Periodic and annual report data is requested from the subrecipient for use in developing the College’s interim and annual reports.
- Subrecipient agreements must be fulfilled both financially and programmatically at the time of the project or agreement closeout.