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Sub-Recipient Monitoring

In accordance with 2 CFR 200.331, as pass-through-entity (PTE), the University must monitor the activities of our subrecipients to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.

The Subaward Life Cycle Flowchart provides an overview of the University’s subaward process

Monitoring activities must include the following:

  1. Reviewing the financial and performance reports required by the University.
  2. 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 PTE detected through audits, on-site reviews, and other means.
  3. Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the University.
  4. Based upon the level of risk posed by the subrecipient, the following monitoring tools may be useful for the University to ensure proper accountability and compliance with program requirements and achievement of performance goals:
    • providing subrecipients with training and technical assistance on program-related matters; and
    • performing on-site reviews of the subrecipient’s program operations;
    • arranging for agreed-upon procedures engagements (See 2 CFR 200.425)
  5. Verify that every subrecipient is audited as required by 2 CFR Subpart F
  6. Consider whether the results of the subrecipient’s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the University’s records
  7. Consider taking enforcement action against noncompliance subrecipients as described in 2 CFR 200.338

See also Subrecipient Monitoring Guide.pdf and AP 8.955 “Subrecipient Monitoring” for specific responsibilities and procedures.