The purpose of this document is to assist UNMC effectively monitor its subrecipients for compliance with applicable laws, regulations, terms, and conditions.
Federal Requirements
In general, federal regulations require UNMC, as the prime recipient, to:
- Advise subrecipients of relevant federal regulations and flow-down provisions from the prime agreement
- Routinely receive and review technical reports
- Routinely receive and review invoices
- Periodically perform on-site visits or make other contact, if necessary
- Review A-133 audit reports filed by subrecipients (or other financial reports), any audit findings, and any corrective actions cited by subrecipients in response to audit findings Perform "audits," if necessary
- Perform examinations, if necessary
- Consider corrective action for subrecipients in cases of serious or continued inability or unwillingness to have required audits or correct non-compliant actions
Please note, this list does not include all sponsor- or program-specific requirements (e.g., human subject assurances).
Roles and Responsibilities
Effective subrecipient monitoring is a collaborative effort among the Department, Sponsored Programs Administration, and Sponsored Programs Accounting. The following pages summarize respective roles and responsibilities. Attachment A provides Guidelines for Classifying a Subrecipient as Low- or High-Risk.
1. Advise subrecipients of relevant federal regulations and flow-down provisions from the prime agreement
The subrecipient agreement serves as the primary tool for advising subrecipients. The agreement is the legal document that formalizes the parties’ agreement, supersedes any previous verbal or other agreements, and serves as the basis for subrecipient monitoring.
Department (i.e., Principal Investigator and/or PI’s designated Departmental Administrator)
- Identifies subrecipients on UNMC’s internal forms (e.g., budget)
- Provides information about consortium arrangement in proposal (e.g., scope of work, budget)
- Negotiates scope of work and budget with co-investigator at subrecipient organization
- Updates Sponsored Programs Administration about changes to proposed consortium arrangement
- Informs Sponsored Programs Administration of special requirements that must be added to subrecipient agreement
- Reviews subrecipient agreement for accuracy and completeness
- Signs subrecipient agreement to signify agreement to terms and conditions
Sponsored Programs Administration
- Maintains subrecipient agreement templates
- Consults with Sponsored Programs Accounting on laws, regulations, and provisions
- Coordinates with Sponsored Programs Accounting on subrecipient classification (e.g., high risk)
- Selects appropriate subrecipient agreement template, based on prime award and subrecipient risk assessment (see Attachment A)
- Generates subrecipient agreement within two weeks of prime award receipt
- Routes subrecipient agreement to Department for review
- Negotiates terms and conditions with sponsored programs office at subrecipient organization
- Tracks status of subrecipient agreement throughout signature process
- Executes subrecipient agreement
- Forwards original executed subrecipient agreement to Sponsored Programs Accounting
Sponsored Programs Accounting
- Responds to inquiries from Sponsored Programs Administration on laws, regulations, and provisions
- Coordinates with Sponsored Programs Administration on subrecipient classification (e.g., high risk)
- Maintains file of original executed subrecipient agreement
- Provides feedback to Sponsored Programs Administration on subrecipient agreements’ terms and conditions as they relate to Sponsored Programs Accounting’s practices
2. Routinely receive and review technical reports
Project participants communicate, formally and informally, through various means, but technical reports are required of subrecipients to document progress.
Department (i.e., Principal Investigator and/or PI’s designated Departmental Administrator)
- Ensure reports are received in a timely manner, at least annually
- Reviews reports for satisfactory progress, and preferably initials and dates reports to signify satisfaction with progress
- Communicates corrective steps needed, if any, to subrecipient, preferably in writing
- Provides copies of written communication regarding corrective steps needed, if any, to Sponsored Programs Administration and Sponsored Programs Accounting
- Sends a copy of final report to Sponsored Programs Administration
Sponsored Programs Administration
- Determines reporting requirements, depending on the prime award, project-specific conditions, and status of subrecipient, at least annually
- Includes appropriate language regarding reporting requirements in subcontract
- Confirms receipt of final report in order to initiate closure
Sponsored Programs Accounting
- Determines whether corrective steps, if any, have been taken before processing any invoices
3. Routinely receive and review invoices
Invoices document a subrecipient’s financial activity on a project and are used as the basis for disbursing funds.
Department (i.e., Principal Investigator and/or PI’s designated Departmental Administrator)
- Reviews invoice for appropriateness, in terms of budget and technical progress, and approves or denies
- Forwards approved invoices to Sponsored Programs Accounting for processing
Sponsored Programs Administration
- Determines invoicing requirements, depending on the prime award, project-specific conditions, and status of subrecipient
- Includes appropriate language regarding invoicing requirements in subcontract
- Provides sample invoice template to subrecipients
Sponsored Programs Accounting
- Confirms whether invoice has been reviewed by Department
- Determines whether expenses have been incurred in compliance with applicable regulations
- Processes approved invoices
- Maintains sample invoice template
4. Periodically perform on-site visits or make other contact, if necessary
When feasible, on-site visits or other contacts (e.g., conference calls) can provide useful information about the subrecipient’s progress. On-site visits by the Department should be distinguished from examinations performed by Sponsored Programs Accounting.
Department (i.e., Principal Investigator and/or PI’s designated Departmental Administrator)
- Identifies need for additional information through visits/contacts
- Includes funds for visits/contacts, if appropriate, in the proposed budget
- Informs Sponsored Programs Administration of any required visits/contacts to include in the subrecipient agreement
- Performs visits/contacts
- Maintains records of visits/contacts
- Provides copies of written records to Sponsored Programs Administration and Sponsored Programs Accounting, should the Department become concerned about the subrecipient’s progress
Sponsored Programs Administration
- Includes any required visits/contacts or required availability for visits/contacts in the subrecipient agreement
- Provides information, as needed, in preparation for visits/contacts
- Proposes and considers corrective actions, should the Department become concerned about the subrecipient’s progress (see #7)
Sponsored Programs Accounting
- Provides information, as needed, in preparation for visits/contacts
- Proposes and considers corrective actions, should the Department become concerned about the subrecipient’s progress (see #7)
5. Review A-133 audit reports filed by subrecipients (or other financial reports), any audit findings, and any corrective actions cited by subrecipients in response to audit findings
A subrecipient’s A-133 audit report is one factor in classifying a subrecipient as low- or high-risk. If the subrecipient is not required to have an A-133 audit, other reports may be substituted.
Department (i.e., Principal Investigator and/or PI’s designated Departmental Administrator)
- Proposes and considers corrective actions, should Sponsored Programs Accounting become concerned about the subrecipient’s audit findings (see #7)
Sponsored Programs Administration
- Confirms in database shared with Sponsored Programs Accounting that subrecipient’s most-recent A-133 audit report (or other financial report) has been reviewed by Sponsored Programs Accounting at least once in the twelve months prior to issuing a subrecipient agreement
- Proposes and considers corrective actions, should Sponsored Programs Accounting become concerned about the subrecipient’s audit findings (see #7)
Sponsored Programs Accounting
- Maintains list of current subrecipients
- Requests copy of A-133 audit (or certification that A-133 audit not required) annually from subrecipient
- Tracks responses to request for copy of A-133 and follows up, as needed
- Reviews A-133 audit (or other financial report) and assesses fiscal soundness
- If material weaknesses found, requests and monitors corrective action plan
- Maintains record of review in database shared with Sponsored Programs Administration
6. Perform examinations, if necessary
When feasible, an examination can provide useful information about the subrecipient’s financial controls. Examinations by Sponsored Programs Accounting, such as a desk audit or on-site visit, should be distinguished from on-site visits by the Department and audits performed by a federal agency or the subrecipient’s accountants.
Department (i.e., Principal Investigator and/or PI’s designated Departmental Administrator)
- Provides information, as needed, in preparation for examination
- Proposes and considers corrective actions, should Sponsored Programs Accounting become concerned about the subrecipient’s financial controls (see #7)
Sponsored Programs Administration
- Provides information, as needed, in preparation for examination
- Proposes and considers corrective actions, should Sponsored Programs Accounting become concerned about the subrecipient’s financial controls (see #7)
Sponsored Programs Accounting
- Identifies need for additional information through examination
- Conducts examination
- Maintains written records of examination
- Provides copies of written records to Department and Sponsored Programs Administration, should Sponsored Programs Accounting become concerned about the subrecipient’s financial controls
7. Consider corrective action for subrecipients in cases of serious or continued inability or unwillingness to have required audits or correct non-compliant actions
Should the Department, Sponsored Programs Administration, and Sponsored Programs Accounting determine that it is in the best interest of UNMC and/or the project to suspend or terminate a subrecipient agreement and/or to preclude any new agreements with that subrecipient, the parties will work together to develop an action plan specific for that subrecipient and/or project.
Department (i.e., Principal Investigator and/or PI’s designated Departmental Administrator)
- Proposes and considers corrective action, including suspending or terminating a subrecipient agreement and/or precluding any new agreements
- Identifies and involves other UNMC stakeholders, including elevation to Chair or Dean, as needed
Sponsored Programs Administration
- Proposes and considers corrective action, including suspending or terminating a subrecipient agreement and/or precluding any new agreements
- Identifies and involves other UNMC stakeholders, including elevation to Vice Chancellor for Research, as needed
- Liaises with project’s sponsor, as appropriate
Sponsored Programs Accounting
- Proposes and considers corrective action, including suspending or terminating a subrecipient agreement and/or precluding any new agreements
- Identifies and involves other UNMC stakeholders, including elevation to Vice Chancellor for Business and Finance, as needed
Appendix A
Guidelines for Classifying a Subrecipient
In database shared between Sponsored Programs Administration and Sponsored Programs Accounting, a subrecipient is assessed on the following factors:
Project-Specific Factors
Sponsored Programs Administration can determine:
- Is there a high level of external oversight by auditors or sponsoring agencies?
- Is the sub-award size, relative to UNMC's award, large?
- Is the sub-award size, relative to other UNMC sub-awards, large?
- Is the project especially complex, involving sensitive issues, or governed by extensive regulations?
Entity-Specific Factors
Sponsored Programs Administration can determine:
- Is the subrecipient debarred or suspended?
- Is the subrecipient a for-profit entity?
- Is the subrecipient a foreign entity?
- Is the subrecipient located remotely from UNMC?
- Is UNMC's prior experience with the subrecipient minimal?
Sponsored Programs Accounting can determine:
- Are the subrecipient's systems and administrative operations rudimentary?
- Is the sub-award size, relative to the subrecipient's sponsored research portfolio, large?
- Is the subrecipient classified as high-risk, per A-133?
- Is UNMC's prior experience with the subrecipient challenging (e.g., an inexperienced subrecipient, having new personnel, or having new or substantially changed systems)?
- Is UNMC's prior experience with the subrecipient non-satisfactory (e.g., a history of non-compliance)?