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SubrecipientMonitoring
Agenda
Reason and Scope Important DefinitionsLife of a SubawardPre-AwardAwardPost-Award
Resources
Reason and Scope
Reason
Federal regulation 2 CFR part 200 “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” Subrecipient Monitoring and Management
§200.330 Subrecipient and Contractor Determinations §200.331 Requirements for Pass-through Entities §200.332 Fixed Amount Subawards
Scope
IU’s Subrecipient Monitoring policy applies to all subawards issued under federal and federal pass-through sponsored projects
However, departments are still responsible for reviewing all subrecipient invoices and other deliverables regardless of prime funding agency.
Important Definitions
Definitions
Pass-through Entity (Prime Recipient): The direct
recipient of sponsored project funds
Subrecipient: The recipient of
sponsored project funds from a Pass-through Entity
Pass-through
Entity (IU)
Prime Funding Agency
Subrecipient2
Subrecipient1
Definitions
Subaward Performance is measured
against the objectives of the federal program
Has responsibility for programmatic decision making
Does not provide goods or services for the program
Is responsible for adherence to applicable Federal compliance requirements
Is usually another higher education institution, hospital, or other non-profit organization
Contractor (Vendor)
Provides goods and services, ancillary to the Federal program, within normal business hours to many different purchasers
Normally operates in a competitive environment
Is not subject to the compliance requirements of the Federal program
Is usually a company or may be an individual
Life of a Subaward
Life of a Subaward Pre-Award Award Post-Award
Pre-Award (Proposal) Stage
Office of Research Administration – Grant Services
Review: Letter of commitment Statement of work Budget and justification F&A rate agreement For non-FDP Public Health Service (PHS) prime
agencies or agencies following PHS guidelines, confirm the subrecipient has a financial conflict of interest policy
Pre-Award (Proposal) Stage
Office of Research Administration – Grant Services
Additional review: Subawards > 70% of the total award Faculty start-up companies Required audit of all federal expenditures if
subrecipient expends over $750,000 in federal funds per fiscal year
Life of a Subaward Pre-Award Award Post-Award
Award Stage
Office of Research Administration – Grant Services
Once per subrecipient per Fiscal Year, the following items are completed: Review the subrecipient’s Single Audit or audited
financial statements Assess the subrecipient’s risk via a Subrecipient Risk
Analysis High-risk subrecipients complete a Subrecipient
Questionnaire
Award Stage
Office of Research Administration – Grant Services
Award Stage
Office of Research Administration – Grant Services
High-risk subrecipients: Notify ORA Grants Finance & Operations and the
Academic Department of the subaward with a high-risk subrecipient Modify the subaward agreement to include
additional supporting documentation requirements based on the subrecipient’s specific circumstances Some example reasons why a subrecipient may be
considered high risk: Foreign No Single Audit or audited financial statements Material weakness or audit finding related to grants
Life of a Subaward Pre-Award Award Post-Award
Post-Award Stage
FMS Accounts Payable
Receive invoice from subrecipient and verify information on the invoice is consistent with the Purchase Order (PO) Ensure expenses are coded in correct object and
sub object codes based on the PO Initiate the payment request (PREQ) document
Post-Award Stage
Academic Departments – Fiscal Officers
Review all invoices prior to approving payment to ensure compliance with the requirements of the subaward For cost reimbursable invoices:
Confirm expenses have been properly classified in major categories
Confirm expenses are reasonable, allocable, and allowable with respect to the award terms
Confirm cost share commitments are met Confirm F&A costs have been calculated correctly Confirm with PI the work is progressing in a
satisfactory manner compared to costs incurred For fixed price invoices:
Confirm the invoice identifies the deliverables/tasks being billed, award amount for each deliverable/task, and any timeline or due dates
Confirm with PI that the deliverable/task has been satisfactorily completed
Post-Award Stage
Academic Departments – Fiscal Officers
For high-risk subrecipients: Confirm all additional supporting documentation
required by the subaward has been included with the invoice prior to approving payment Examples of additional supporting documentation
may include: Detailed transaction listing Labor detail Payroll certification records Receipts
Post-Award Stage
Academic Departments – Fiscal Officers
Confirm that the payment against the invoice is posted to the correct subrecipient, account number, object code, and sub object code
Retain documentation of review An example: email correspondence regarding PI approval
that work has been completed satisfactorily compared to costs incurred on an invoice
Subrecipients on accounts that have indirect costs
First $25,000 in expenses 4074
Expenses over $25,000 4075
Expenses over $25,000 when F&A is charged on entire subcontract (TDC) 4077
Subrecipients on accounts that do NOT have indirect costs
First $25,000 in expenses 4073
Expenses over $25,000 4075
Post-Award Stage
Academic Departments – Fiscal Officers
If any information is missing, is incorrect, or if there is an unallowable expense included in the invoice: Place the payment request on hold or request that
AP cancel the payment request Contact the subrecipient for additional supporting
documentation or other necessary resolution Inform ORA (Caitlin Homenda – [email protected]) of
any disallowance
Post-Award Stage
Academic Departments – Principal Investigators (PIs)
Review technical performance reports or other specified deliverables in a timely manner For cost reimbursable invoices, confirm that the work is
progressing in a satisfactory manner compared to costs incurred For fixed price invoices, confirm that the billed
task/deliverable has been completed and is acceptable Retain documentation of review
Post-Award Stage
Office of Research Administration – Grants Finance & Operations (GFO)
For high-risk subrecipients: Subawards ≥ $150,000 per year
Schedule meeting with fiscal officer and PI to discuss policy requirements
Sample the first subrecipient invoice to confirm additional supporting documentation is received and accuracy of the invoice
Subawards < $150,000 per year Send email to the fiscal officer and PI to discuss policy
requirements Sample the first subrecipient invoice to confirm additional
supporting documentation is received and accuracy of the invoice
GFO may select more samples throughout the project period depending on the specific circumstances of the subrecipientand department
Resources
Resources
External Resources
Federal regulation 2 CFR part 200 “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” http://www.gpo.gov/fdsys/pkg/FR-2013-12-
26/pdf/2013-30465.pdf Subrecipient Monitoring and Management section
begins on page 47
Resources
Internal Resources
Office of Research Administration Website Proposal Preparation and Submission
http://researchadmin.iu.edu/GrantContract/gc-propprep/gcs_subcontract.html
Grants Finance & Operations Subrecipient Monitoring http://researchadmin.iu.edu/GrantContract/gc-
gfo/gfo_sub_monitoring.html Subrecipient Monitoring Post Award Procedure Guide
http://researchadmin.iu.edu/GrantContract/docs/gfo_docs/Subrecipient_Monitoring_Post_Award_Procedure_Guide.pdf
Indiana University Policies Website Subrecipient Monitoring Policy
http://policies.iu.edu/policies/categories/research/Sponsored-Programs-Administration/Subrecipient_Monitoring.shtml
Resources
Resources
Resources
Questions?
Contact Information
Caitlin Homenda
Sr. Financial Compliance Analyst
Grants Finance & Operations
Office of Research Administration
Phone: 812-855-9122
Email: [email protected]
