Sub-Recipient Monitoring Policy

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Background

The Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Final Rule, 2 CFR 200,  Dec. 26, 2014, ("Uniform Guidance") sets forth standards for obtaining consistency and uniformity in organizations expending Federal awards. In instances where the award recipient subcontracts with another organization to perform duties required or necessitated by the research award, the award recipient is considered to be a pass-through entity. As a pass-through entity, the award recipient has monitoring obligations to ensure that the sub-recipient uses the award for authorized purposes and that the goals of the award are achieved.

Purpose

The purpose of this policy is to define subawards, identify roles and responsibilities for those requiring subrecipient monitoring, and provide guidance in fulfilling those responsibilities for grants and sponsored programs.

Definitions

A "subrecipient" is the legal entity to which a subaward is made and which is accountable to Davidson College for the use of the funds provided in carrying out a portion of the programmatic effort under a sponsored project.

A "subaward" is an award of financial support from Davidson College ("prime recipient") to a qualified organization for the performance of a substantive portion of the program funded under the prime award.  It does not include procurement of goods and services funded by a prime award, i.e., vendors are not considered subrecipients.

Policy

In accordance with Uniform Guidance 200.331, as a pass-through entity, Davidson College will ensure the following as it relates to the subrecipients of federal funds.

A. Ensure the subrecipient has not been Suspended or Debarred by the federal government by checking the System for Award Management web site (www.sam.gov). The Office of Sponsored Programs will document the Suspension and Debarment verification by including a screen print of the Exclusions search in the subaward file.

B. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information:

  1. Federal Award Identification
    • Subrecipient Name (must match the DUNS number)
    • Subrecipient DUNS number
    • Federal Award Identification Number (FAIN)
    • Federal Award Date
    • Sub-award Period of Performance Start and End Date
    • Amount of Federal Funds obligated by this action
    • Total Amount of Federal Funds Obligated to the subrecipient
    • Total Amount of the Federal Award
    • Federal Award Project Description
    • Name of Federal Awarding Agency
    • Name of Pass-Through Entity (Davidson College)
    • Contact information for awarding official
    • CFDA Number and Name
    • Identification of whether the award is R&D
    • Indirect Cost Rate for the Federal Award
  1. Flow-down requirements imposed on subrecipient
  2. Any additional requirements imposed on subrecipient
  3. Subrecipient's federally-negotiated indirect cost rate agreement
  4. A requirement that the subrecipient permit Davidson College auditors access to the subrecipient's records and financial statements as necessary for audit requirements.
  5. Appropriate terms and conditions concerning closeout of the subaward.

C. Evaluate each subrecipient's risk for noncompliance to determine appropriate monitoring procedures.

D. Consider specific subaward conditions as appropriate.

E. Monitor activities as necessary to ensure compliance with federal regulations.

  • Review financial and programmatic reports.
  • Follow up on audit findings to ensure timely and appropriate action.
  • Issue a management decision for audit findings.

F. Determine monitoring tools as appropriate based on risk assessment.

G. Ensure that each subrecipient is audited by 200.501 Subpart F - Audit Requirements.

H. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to Davidson College's own records.

I. Consider taking enforcement action for noncompliance.

Administration of Policy

The Director of Sponsored Programs shall oversee this policy and review it at least once every two years.  Changes to this policy shall be made in accordance with the College's Policy on Policies.

Adopted: May 3, 2015

Last Revised: April 15, 2021

Last Reviewed: April 15, 2021