Subrecipient monitoring procedure

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:

  1. Advise subrecipients of relevant federal regulations and flow-down provisions from the prime agreement
  2. Routinely receive and review technical reports
  3. Routinely receive and review invoices
  4. Periodically perform on-site visits or make other contact, if necessary
  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 Perform "audits," if necessary
  6. Perform examinations, if necessary
  7. 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)

Sponsored Programs Administration

Sponsored Programs Accounting

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)

Sponsored Programs Administration

Sponsored Programs Accounting

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)

Sponsored Programs Administration

Sponsored Programs Accounting

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)

Sponsored Programs Administration

Sponsored Programs Accounting

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)

Sponsored Programs Administration

Sponsored Programs Accounting

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)

Sponsored Programs Administration

Sponsored Programs Accounting

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)

Sponsored Programs Administration

Sponsored Programs Accounting

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:

Entity-Specific Factors

Sponsored Programs Administration can determine:

Sponsored Programs Accounting can determine: