Subrecipient Monitoring and Management

Catalog Number

011

Scope

In accordance with Uniform Administrative Requirements 2 CFR 200.331, as a pass-through entity, UMA is required to evaluate each subrecipient’s risk of non-compliance in order to determine the appropriate level of subrecipient monitoring. With each risk assessment, UMass may consider imposing specific subaward conditions. Ongoing monitoring ensures that subawards are used for authorized purchases, in compliance with Federal statutes, regulations, and terms and conditions of the subaward. This policy applies to all Federal subawards.

Purpose

This policy outlines how UMass Amherst (UMA) assesses risk and monitors subrecipients of Federal subawards in accordance with Uniform Administrative Requirements 2 CFR 200.331.

Definitions

Pass Through Entity – A pass-through entity is a non-federal organization that receives a federal award and passes the award to a subrecipient.
Risk Assessment – A systematic process of evaluating another entity for potential complications or default prior to issuing a subrecipient agreement.
Subaward – An award provided by a pass-through entity to a subrecipient to carry out part of a Federal award received by the pass-through entity.
Subrecipient – A non-federal entity that receives a subaward to carry out part of a Federal award.
Subrecipient Monitoring – Monitoring the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purchases, in compliance with Federal statues, regulations, and terms and conditions of the subaward.

Policy

The UMA Controller’s Office (Compliance Unit) conducts risk assessments for subrecipients prior to the Office of Post Award Management (OPAM) executing a Federal subaward. As a part of proposal documentation, each potential subrecipient is required to complete a UMA Subrecipient Form. This form provides essential details needed to make subrecipient vs. contractor determinations and to complete a risk assessment. OPAM prepares all subrecipient agreements and includes additional terms as suggested by the Controller’s Office if the risk assessment determines a subaward to be high risk.

Risk is assessed in Kuali with an online risk assessment form. Risk is determined based on numerous factors including whether a subrecipient is domestic or foreign, receives a single audit, has prior experience with Federal awards, the amount of funding to the subrecipient, etc.

Some of the additional terms which may be used for high risk subawards are:

Invoicing which requires additional expense details/backup
Awarding one year at a time
Withholding automatic carryover of unused balances from one budget period to the next

Some of the additional oversight by the Principal Investigator (PI) and/or Controller’s Office for high risk subawards:

PI maintains more frequent contact for progress updates
Both the PI and Controller’s Office (Compliance Unit) review invoices to ensure additional invoicing terms are met according to the subaward agreement
Site visits of program operations when necessary
Additional training and technical assistance offered to Subrecipient on program and/or invoicing related matters
Annual risk assessment prior to amendments

Monitoring activities such as these are documented and retained. In rare instances, The Controller’s Office (Compliance Unit) may determine that the risk of a subaward is very high and advise that the subaward agreement not move forward. The Controller’s Office will notify the PI of the risk assessment and set up a meeting with PI and OPAM to further discuss the risk and make a final determination with OPAM and the PI about how to proceed.

Standard subrecipient monitoring and management measures for all Federal subawards issued include:

Initial risk assessments
Additional terms are added to the agreement if a Subaward is determined to be high risk

Compliance monitors timely routing and approval of invoices received at rainvoices@admin.umass.edu and reviewed by the Controller’s Office to ensure invoicing terms are met prior to routing via DocuSign to department for PI approval
PI reviews and authorizes invoices to ensure that the subaward is being used for authorized purposes and in compliance with award terms and conditions.
PI receives and accepts timely technical reports and deliverables

Annual review of single audit by the Controller’s Office (Compliance Unit)
Continuing annual risk assessment for high risk entities
Issue management decisions on audit findings pertaining to UMass Subawards within 6 months after acceptance of the audit report by the FAC
Communication between OPAM, Controller’s Office and PI department on any concerns that may arise with active or pending subrecipients