Federal Grant Subaward Risk Assessment and Monitoring Policy

Responsible Office or Person: Provost Office
Related Law & Policy: CFR 200.330 to 200.331, 200.338, 200.425, 200.501, 200.521

Scope

This policy applies to Carroll University subawards supported by federal funds to ensure compliance with the Uniform Guidance (2 CFR 200) for subawards issued to other institutions for which Carroll is the pass-through entity (PTE).

Definitions

Pass-through entity (PTE): A non-federal entity that provides a subaward to a subrecipient to carry out part of a federal program; also referred to as the prime or lead awardee or institution.

Recipient: A non-federal entity that receives a federal award directly from a federal awarding agency to carry out an activity under a federal program; does not include subrecipients.

Subaward: An award provided by a PTE to a subrecipient for the subrecipient to carry out part of a federal award received by the PTE; does not include payments to contractor or payments to an individual that participates in/benefits from a federal program.

Subrecipient: A non-federal entity that receives a subaward from a PTE to carry out part of a federal program; does not include a contractor or an individual that participates in/benefits from such a program.
 

Compliance

Subrecipient Risk Assessment Policy:
Prior to issuing the award as the pass-through entity (PTE), an assessment of the subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward must be completed for the purposes of determining the appropriate level of subrecipient monitoring. Consideration of such factors include:
  1. The subrecipient’s prior experience with the same or similar subawards;
  2. The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F – Audit requirements, and the extent to which the same or similar subaward has been audited as a major program;
  3. Whether the subrecipient has new personnel or new or substantially changed systems; and
  4. The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency.)
Subrecipents will be assessed by grants staff, with additional review by the Associate Vice President for Finance and Administration and University Risk Manager as necessary.

Subrecipient Monitoring Policy:
Subrecipient monitoring can take on various forms and is not limited to the practices described below. 2 CFR 200 outlines the following forms of monitoring activities necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward.
Monitoring of the subrecipient must include:
  1. Reviewing financial reports required by the pass-through entity (Business Office).
  2. Reviewing performance reports required by the pass-through entity (Grants Staff).
  3. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means (PI, Grants Staff, and Business Office).
  4. Issuing a management decision for audit findings pertaining to the Federal award provided to the Subrecipient from the pass-through entity as required by 2 CFR 200.521 (Business Office).
  5. Verify that every subrecipient is audited as required by Subpart F – Audit requirements of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set form in 2 CFR 200.501(Business Office).
  6. Consider where the results of the subrecipient’s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity’s own records (Business Office and Grants Staff).
  7. Consider taking enforcement action against noncompliant subrecipients as described in 2 CFR 200.338 (Business Office and Grants Staff).
Depending on the results of the subrecipient’s risk assessment, the following monitoring tools may be used to ensure proper accountability and compliance with program requirements and achievement of performance goals:
  1. Providing subrecipients with training and technical assistance on program-related matters;
  2. Performing on-site reviews of the subrecipient’s program operations;
  3. Arranging for agreed upon procedures engagements as described in 2 CRS 200.425.
Procedure:
  1. Complete the subaward data collection form to initiate the subcontract (Grants Staff).
  2. Assess the risk of the subrecipient (Business Office).
  3. Determine the frequency and scope for monitoring programmatic activities of the subrecipient, to include regular contact with the subrecipient and review of annual programmatic reports (Business Office and Grants Staff).
  4. Ensure subrecipients comply with the technical provisions of the subaward (Business Office and Grants Staff).
  5. Monitor subawards to insure that costs are appropriate. This includes requesting and tracking subrecipient financial reports (PI and Business Office).
  6. Keep detailed records of any communication regarding subrecipient monitoring, such as reviewing reports, including any unsatisfactory performance by the subrecipient (PI, Business Office and Grants Staff).
  7. Consider subaward amendments where needed (Business Office and Grants Staff).


 

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