subrecipientmonitoring

The United States Office of Management and Budget has issued Circular No. A-133, which was revised to show changes published in the Federal Register June 27, 2003. It deals with audits of states, local governments, and non-profit organizations.

Sub-recipient Monitoring for OMB Circular A-133

Audits of states, local governments, and non-profit organizations: this outlines how auditors conduct annual compliance audits and what the audits must cover.

Contains additional compliance requirements for “Sub-recipient monitoring” and defines and describes “who” a sub-recipient is, compared to a “vendor”.

Understanding these definitions will directly impact the proposal budget development, the selection of the appropriate agreement document to use and the correct usage of accounting “subcodes”.

The “Sub-recipient’s” performance is measured against meeting federal program objectives. They have a responsibility for programmatic decision-making. They are in charge of who we have “sub-awarded” funds to, who uses those funds to “carry out” a program. They work in collaboration with us.
The “Vendor” provides these kinds of goods and services within normal business operations, to many different purchasers. They normally operate in a competitive environment and have no programmatic decision-making authority.
The ultimate university responsibility is to ensure “sub-awarded” funds, monitor sub-recipient activities to ensure that funds are used for authorized purposes in compliance with federal program regulations and terms of the prime award and that performance goals are achieved.

Sub-recipient Monitoring for Sub-agreements

Once the sub-recipient situation is determined the correct agreement document should be selected. Since your award transactions are serviced and processed through RCUH, you must process for their execution. Remember that UH is still responsible for the sub-agreement, even though execution is through RCUH. We will be requiring sub-recipient information prior to agreement and PO execution.
There are currently two sub-agreement templates being recognized for execution. The first is the FDP “Sub-award Agreement” template, available on their website. Second is the “Subcontract Agreement” available on the RCUH website.
We recommend using the FDP document for sub-awards from our university prime grant award and the document already in use by other FDP participating institutions.
Do not use the “Agreement for Services” template available on the RCUH website because this is primarily used for vendors and consultants because it doesn’t contain basic elements needed to comply with A-133.
The necessary elements to comply with A-133 are:
1) the award name, number, CFDA number and name of sponsor (“Subcontract Agreement….1st whereas)
2)Budget attachment (“Subcontract Agreement….4th whereas)
3) A-133 audit requirement (clause #5)
4) Right to access and examine records (clause #6)
5) Recourse for disallowed costs (Clause #8)
6) Other clauses/ special provisions as applicable.
Other clauses or special provisions to consider include:
1) Cost sharing or matching (There is a need to clearly communicate how sub-recipient is to report information to us and how frequently.), and
2) Acquiring “Federally-owned” equipment (There is a need to clearly communicate how sub-recipient is to report information to us and how frequently.)