The following are the procedures the Amherst Campuses follows to achieve OMB Circular A-133 compliance with monitoring subrecipients.
1. All subrecipient grants and contracts are issued by the Office of Grants and Contracts Administration (OGCA). The terms and conditions of the sub-awards (term includes sub-contracts) advise subrecipients of requirements imposed on them by Federal laws and regulations.
2. The Controllerís Office budgets each sub-award under PS account code 757270 for the portion of the sub-award over $25,000 and PS account code 757275 for the portion $25,000 or under. The PS account codes control charging of indirect.
3. The Controllerís Office notifies the PI of receipt of a sub-award, and the PIís staff creates a PO and sends to the subrecipient with a copy of the sub-award. The PO is encumbered on the Project Grant by the Controllerís Office.
4. Subrecipient invoices are sent to either the PI, or to the Controllerís office who forwards to the PI with a cover memo instructing the PIs to review the appropriateness of the expenditures and ensure all technical and progress reports are submitted before approving the invoice. PI signs the invoices approving payment and certifying appropriateness of expenses.
5. Quarterly starting in December, the Controllerís Office run PS queries on open sub-award POs and all sub-award expenses in the fiscal year. Information regarding whether the subrecipient has met audit requirements for the prior fiscal year is obtained via emails, letters or by searching the Federal Clearinghouse or the subrecipientís web-site for an A-133 audit report.
6. Subrecipient data is recorded on an Excel© spreadsheet and follow-up conducted periodically by one or more of the following methods for non-responses: a. 2nd request emails or letters are sent. b. Search of Federal Clearinghouse c. Search of Subrecipient Web site.
7.For each subrecipient with material noncompliance and or reportable conditions, the Controllerís Office obtains the audit report and reviews the findings, determines if there is any impact on sub-awards from UMAMH, and if so, evaluates the corrective action plan for resolution.
8. The Controller's Office may perform a desk audit of selected invoices from the subrecipient to ensure accuracy and allowability of the charges. If the subrecipient had any major findings in any of their audits, that subrecipient will be selected for a desk audit.
9. Annually the Controller will remind all PIs that Circular A-133 Subrecipient Monitoring guidelines require the PI to monitor the activities of subrecipients to ensure that performance goals stipulated in the sub-award are achieved.
Last Updated: 08/20/13