In recent years, Federal Agencies have placed increased scrutiny on institutional compliance with subrecipient monitoring regulations as required by OMB Circulars A-110 and A-133. Yale recently issued Procedure 1307 PR.01 “Monitoring Subrecipient Activity Associated with Sponsored Programs" which is intended to ensure that all members of the University community who are involved in the conduct of sponsored research are familiar with a) the requirements associated with subrecipient monitoring and b) the process by which the University will comply with these requirements.
The University has implemented a risk-based methodology to manage subrecipient agreements. The new procedure implements this methodology by defining both the standards to be used for stewardship of sponsored funds and the roles and responsibilities associated with subrecipient monitoring
Effective subrecipient monitoring is a collaborative effort among the Principal Investigator (PI), the department business office, Grant and Contract Administration (GCA) and Grant and Contract Financial Administration (GCFA). The process actually begins prior to issuance of the subaward and extends through the life of the agreement. Prior to negotiating and executing a subrecipient agreement GCA will conduct a risk assessment of a subrecipient. Risk assessments that reveal a high level of risk will require an appropriate risk mitigation plan which will be developed in consultation with the requesting investigator and department. Annually, GCFA will monitor subrecipient financial stability, financial processes and controls on all existing subawards.
Ongoing monitoring at the departmental level includes review of invoices for appropriate information, review of subrecipient scientific progress, and review of formal technical reports and deliverables. The procedure recommends the approach PIs and department business managers should take with regard to the frequency and scope of monitoring activities To assist departments in this regular monitoring activity GCFA will regularly review subrecipient invoices to ensure allowability, allocability and reasonableness prior to payment.
GCFA has also recently instituted a “desk review” program of subawards issued to collaborating institutions/organizations. The primary reasons for these periodic, random reviews is to ensure that appropriate periodic monitoring of the subrecipient is being performed and that Yale PIs are satisfied with the work being accomplished and are able to share any issues or concerns they may have. These reviews are intended to be a collaborative process with PIs and business office staff and are meant to ensure that Yale is fulfilling its obligations to the prime sponsor.
Take a few minutes to review and familiarize yourself with the Procedure 1307.