SUBRECIPIENT MONITORING

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SUBRECIPIENT MONITORING

• LeAnn S. Forsberg
• Director, Office of Grant and Contract Management
• The University of North Texas Health Science
  Center at Fort Worth

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Synopsis

• Terminology
• Pre-Award Issues
• Negotiation / Standard Subcontracts
• Monitoring
• Close out

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Subrecipient The A-133 Definition

• A non-federal entity that expends federal awards
  received from a pass-through entity to carry out
  a Federal program..
• Subrecipient or Vendor THAT IS THE QUESTION
• Substance of the relationship is more important
  than the form of the agreement
• Determination based on judgment of the particulars

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Typical Attributes of Subrecipient

• Prime determines who is eligible
• Performance measured against objectives of
  Federal program
• Responsibility for programmatic decision making
• Responsibility for adherence to applicable
  federal program compliance requirements
• Uses Federal funds to carry out program of
  organization as compared to providing goods or
  services

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Consultants Are Not Subrecipients

• Consultant ancillary to project independent
  expertise
• Individual not organization
• No employer/employee relationship
• No salaries no overhead, fringe benefits

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The Prime Relationship

• Prime accountable to Sponsor
• Subrecipient accountable to Prime
• Secondtier sub accountable to Subrecipient,
  etc.

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Subrecipient or Subcontract??

• When the Prime Agreement is a Contract, the
  Subrecipient Agreement is a Subcontract
• When the Prime Agreement is a Grant, the
  subrecipient is a technically a subgrant but
  is often referred to as a Subaward or a
  Subcontract

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Governing Regulations Federal Contract

• A-21 Cost Principles
• Federal Acquisition Regulations (FARs) watch
  for agency specific FARs e.g. DFARS are Defense
  Department FARS
• Regulations that govern the prime usually flow to
  subcontractor, except commercial to university,
  use different FARs

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Governing Regulations Federal Grant

• A 21 Cost Principles
• A-110 Administrative Regulations for Colleges,
  Universities, Hospitals and other Nonprofit
  Organizations
• Terms Conditions of Prime Grant usually flow to
  Subrecipient

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Pre-Award Issues

• Communicate with the PI
• Decision to use subagreement
• Preliminary information on external institution
• Budget/budget justificationWhere a subrecipient
  fits and its impact on the budget
• Start risk assessment

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Pre-Award Issues

• Communicate with external institutions
• Confirm all contact information for external
  institutions PI, institutional official, and
  administrative liaison
• Share all program guidelines, instructions, and
  formats

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Pre-Award Issues

• Minimum information needed from a subrecipient
• Statement of work to be performed
• Budget prepared using the budget format and level
  of detail required by the agency
• Completed reps and certs (if required)
• Signature of an authorized official signifying
  their intent to complete the project if funded

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Negotiation / Standard Agreements

• Which Subrecipient Agreement to use
• Institutional Standard
• National Subaward Model Agreement Form FDP
  Model
• Communicate with PI to ensure there have been no
  changes since the proposal

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Negotiation / Standard Agreements

• Structure of Subaward Institutional Standard
• Relevant institutional information
• Scope of work
• Reporting Requirements
• Type of subaward
• Reimbursement process

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Negotiation / Standard Agreements

• National Subaward Model Agreement Form FDP
  Model
• http//www.thefdp.org/Subawards_Forms.html
• FDP Versions and Non FDP versions with
  attachments for both

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Monitoring

• Prime Institution is required to determine
• Subrecipient is eligible (not debarred)
• Have appropriate financial systems to manage
  grants
• No outstanding audit issues
• Receive, review and pay invoices
• Monitor technical progress
• Audit or site visit if necessary

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Monitoring

• A-133 Compliance Supplement (Part 3, Section M)
• Three factors that affect the extent of
  monitoring (the risk)
• Program complexity
• Percentage passed through
• Amount of award

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Monitoring

• Based on the subrecipient risk
• Reporting
• Level of detail and review of financial and
  technical reports
• Site Visits
• On site review of financial and programmatic
  records and operations
• Regular Contact
• Audits

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Close out

• Required reports have been received and acted
  upon
• Subrecipient has been paid (reviewed final
  invoice)
• Invention Reports are completed
• Property management review (as needed)
• Desk Review or more if needed