Transcript Subrecipient Monitoring

Subrecipient
Monitoring
Agenda
Reason and Scope
Important Definitions
Life of a Subaward
Pre-Award
Award
Post-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
 Pass-through Entity
(Prime Recipient):
Definitions
Prime
Funding
Agency
 The direct
recipient of
sponsored project
funds
Passthrough
Entity (IU)
 Subrecipient:
 The recipient of
sponsored project
funds from a Passthrough Entity
Subrecipient
Subrecipient
1
2
Definitions
Subaward
Contractor (Vendor)
 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
 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
Office of Research Administration – Grant Services
 Review:
Pre-Award
(Proposal)
Stage
 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
Office of Research Administration – Grant Services
Pre-Award
(Proposal)
Stage
 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
Office of Research Administration – Grant Services
 Once per subrecipient per Fiscal Year, the following
items are completed:
Award Stage
 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
Office of Research Administration – Grant Services
Award Stage
Office of Research Administration – Grant Services
 High-risk subrecipients:
Award Stage
 Notify ORA Grants Finance & Operations and the
Academic Department of the subaward with a highrisk 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
FMS Accounts Payable
Post-Award
Stage
 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
Academic Departments – Fiscal Officers
 Review all invoices prior to approving payment to
ensure compliance with the requirements of the
subaward
 For cost reimbursable invoices:
Post-Award
Stage
 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
Academic Departments – Fiscal Officers
 For high-risk subrecipients:
Post-Award
Stage
 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
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
Subrecipients on accounts that have indirect costs
Post-Award
Stage
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
 Retain documentation of review
 An example: email correspondence regarding PI approval
that work has been completed satisfactorily compared to
costs incurred on an invoice
Academic Departments – Fiscal Officers
 If any information is missing, is incorrect, or if there
is an unallowable expense included in the invoice:
Post-Award
Stage
 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
Academic Departments – Principal Investigators (PIs)
Post-Award
Stage
 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
Office of Research Administration – Grants Finance &
Operations (GFO)
 For high-risk subrecipients:
 Subawards ≥ $150,000 per year
Post-Award
Stage
 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 subrecipient
and department
Resources
External Resources
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-2013-1226/pdf/2013-30465.pdf
 Subrecipient Monitoring and Management section
begins on page 47
Internal Resources
 Office of Research Administration Website
 Proposal Preparation and Submission
 http://researchadmin.iu.edu/GrantContract/gcpropprep/gcs_subcontract.html
 Grants Finance & Operations Subrecipient Monitoring
Resources
 http://researchadmin.iu.edu/GrantContract/gcgfo/gfo_sub_monitoring.html
 Subrecipient Monitoring Post Award Procedure Guide
 http://researchadmin.iu.edu/GrantContract/docs/gfo_d
ocs/Subrecipient_Monitoring_Post_Award_Procedure_
Guide.pdf
 Indiana University Policies Website
 Subrecipient Monitoring Policy
 http://policies.iu.edu/policies/categories/research/Spon
sored-ProgramsAdministration/Subrecipient_Monitoring.shtml
Resources
Resources
Resources
Questions?
Caitlin Homenda
Sr. Financial Compliance Analyst
Contact
Information
Grants Finance & Operations
Office of Research Administration
Phone:
812-855-9122
Email:
[email protected]