Subrecipient Monitoring: Riding The Storm OutPresentation Transcript
Subrecipient Monitoring: Riding The Storm Out Tom Egan, MIT OSP Bethanne Giehl University of Massachusetts Medical School
What is a subrecipient
OMB Compliance Requirements
Subrecipient Monitoring Classes
Subrecipient Monitoring Approaches
A-133 Audit Report Review
Subrecipient Monitoring Financial
Subrecipient Monitoring Technical
DEFINITION OF SUBRECIPIENT
Financial assistance, or procurement, or contract made by a recipient to an eligible subrecipient
Includes any financial assistance when provided by legal agreement, even if the agreement is called a contract
Does not include the purchase of goods and services
DEFINITION OF SUBRECIPIENT
The legal entity to which a subaward is made and which is accountable to the recipient for the use of funds provided.
See agency implementations of A-110 to determine what type of entity can be a subrecipient.
Note guidance on distinguishing between subrecipient and a vendor.
Funding from a prime recipient to a subrecipient to carry out specific program activities.
May be termed a subgrant from an assistance award
May be termed a subcontract from a procurement award
The term “subrecipient” and “subawardee” are used interchangeably.
OMB Compliance Requirements:
Attachment M Subrecipient Monitoring
The March 2004 Compliance Supplement was revised to clarify OMB’s expectations related to subrecipient monitoring .
Annual request for subrecipient’s A-133 report is not sufficient.
On-going review and oversight are expected and may include:
-Reviewing financial and performance reports
-Performing site visits to review information and observe operations
-Regular contact and appropriate inquires
Subrecipient Monitoring: Classes
Four “Classes” of Subrecipients
Not-for-profits with Federal expenditures in excess of $500,000
Not-for-profits with Federal expenditures less than $500,000
Non US-based entities
Subrecipient Monitoring: Approaches
Factors such as the size of awards, percentage of the total program's funds awarded to subrecipients, and the complexity of the compliance requirements may influence the extent of monitoring procedures
Research and review results of subrecipient’s OMB Circular A-133 audit reported in the Federal Audit Clearinghouse. This is the primary monitoring step for the Research Administrator. Information presented within Federal Audit Clearinghouse is relied upon as sufficient evidence of compliance with the provisions of OMB Circular A-133 if the organization:
Receives an unqualified opinion on the financial statements
Receives an unqualified opinion on internal controls
Has no material weaknesses reported
Has no reportable conditions related to Federal awards
http://harvester.census.gov/sac/dissem/accessoptions.html?submit=Retrieve+Records FEDERAL AUDIT CLEARINGHOUSE
For subrecipients not listed in the Federal Audit Clearinghouse, the Research Administrator should make inquiries by forwarding a confirmation request letter to determine whether an audit was required and, if so, the status of the audit. Retain copy of inquires and complete 2nd and subsequent inquiries as needed to acquire audit information.
Subrecipient Monitoring: A-133 Audit Report Review MIT’s response to subrecipient’s audit status query
For subrecipients that are identified with a reportable condition, gain an understanding of relevant findings or questioned costs stated in the Federal Audit Clearinghouse and/or request a copy of the subrecipients A-133 report with all appendices.
Upon receipt of applicable information, evaluate for materiality, any findings or questioned costs noted during the above procedures. Consider the impact of any corrective action plan as well as other related actions undertaken by subrecipient management. Notify the proper Institute administrative departments of those findings and questioned costs determined to have a material impact on Federal awards.
Subrecipient Monitoring: FINANCIAL
Track subrecipient allocations separately
Process for review and approval of invoices
PI for programmatic
OSP for administrative/financial
Reimbursement for disallowances
Verify cost sharing commitments
Subrecipient Monitoring: TECHNICAL
Timely submission of deliverables
OMB Circular A-21
OMB Circular A-110
OMB Circular A-133
FDP Subrecipient Template
Catalog of Federal Domestic Assistance (CFDA)
QUESTIONS AND COMMENTS
FDP Homepage: http://TheFDP.org/
FDP Subaward Demonstration Project:
FDP Subaward Agreement Forms
Lists of Parties Excluded from Federal
Procurement & Nonprocurement Programs
Federal Audit Clearinghouse: http://www.harvester.census.gov/sac/
MIT Office of Sponsored Programs: http://web.mit.edu/osp/www