Purpose:
To establish guidelines for sub-recipient monitoring and management on sponsored awards and contracts which are consistent with federal, state, city, and private grantor regulations. This policy is intended to comply with the requirements from the Office of Management and Budget Uniform Guidance (UG) requirements for pass-through entities section 200.331 as well as requirements from our federal/non-federal sponsors.
Scope:
This policy is applicable to faculty and staff who are involved in administering sponsored awards and contracts.
Responsibility:
The interpretation and administration of this policy shall be the responsibility of the Grants and Contracts Accounting Office (GCA) in consultation with the Director of the Office of Sponsored Programs (OSP) and the Associate Vice President and Controller.
Policy:
This policy applies to all sponsored awards and contracts at Teachers College (TC). TC evaluates and monitors the financial and programmatic performance of sub-recipients and assesses their capacity to properly manage a sub-award. The College’s objective is to monitor that sponsor funds are properly spent, that performance goals are met, and that Sub-recipients comply with all applicable law, regulations, and prime award terms. The College may impose specific controls, as needed, for certain sub-recipients based on relevant risk factors. The terms of the sub-recipient’s relationship with the College must be documented in a written sub-award agreement between TC and the sub-recipient organization.
Procedures for Sub-Recipient Monitoring and Management
The Principal Investigators (PI’s), OSP, and GCA will work on the following:
The College maintains a sub-recipient monitoring system consisting of an award and application process and a system of periodic monitoring of sub-recipients. The grant application and award process is handled by the Office of Sponsored Programs and is ultimately executed by the Provost, who is responsible for authorizing all contracts.
GCA is in charge of monitoring any changes in regulations and requirements of all federal/non-federal programs. If there are any changes, GCA is responsible to communicate the changes to the respective PI and their department as well as the sub-recipient receiving the funds. The PI and their department are also in constant communication with the sub-recipient and any changes in the environment, financial, new programs, or restructuring quickly identified so that the GCA is alerted.
As part of the monitoring process, an assessment of risk is performed prior to making sub-awards to sub-recipients by using a universal sub-recipient contractual agreement to ensure that the sub-recipient is fully aware of the terms and conditions of the sub-award, and who is required to countersign and return a copy of the contract to OSP. A Sub-recipient Information & Compliance Form is filled out stating the sub-recipients must provide: copy of most recent Single Audit, copy of F&A Rate, Financial Status Questionnaire (If applicable), IRB Approval & Informed Consent (If applicable), Certifying no debarment, suspension, proposed debarment of sub-recipient and financial conflict of interest policy. GCA is required to understand the sub-recipient’s intentions, controls, and major changes in the sub-recipient environment. This allows GCA to be aware of any changes that may affect the use of grant funds.
Applications for the grant are approved by the PI and then the GCA sets the sub-award up in BANNER assigning the appropriate index to the program. If the contract is federal and is valued greater than or equal to $25,000, data of the contract must be entered in www.USASpending.gov per the Federal Funding Accountability and Transparency Act (FFATA). This information is entered by GCA.
The College sends standard award documents to the sub-recipient that inform them of the purpose of the grant, the payment cycle, the intended use of the funds, and compliance requirements. GCA retains copies of all documentation related to the grant from inception and the PI and their department retains all originals. The PI and their department periodically check in with sub-recipients with respect to uses of the fund, major transactions, and the overall progress of the program.
On a periodic basis, the PI and the Department along with GCA, discuss the internal control policies in place for sub-recipients. For example, if a risk factor increases due to matters previously communicated between the PI and sub-recipient, the group may determine further monitoring procedures are needed to ensure appropriate compliance is maintained.
Expenses submitted for reimbursement by the subcontractors are forwarded to the PI and reviewed for compliance with contractual items by GCA, and are subjected to the same system of internal controls as similar procurement transactions.
GCA is responsible for the Federal Single Audit portion of the monitoring process. A universal form adopted by the College is used to ensure that sub-recipients timely submit their Single Audit reports. Upon receipt of the report, it is reviewed to ensure there are no findings related to the respective federal sub-awards, or if applicable, that a corrective action plan and status report are received pursuant to those findings.
Definitions
A "sub-recipient" is the legal entity to which a sub-award is made and which is accountable to Teachers College for the use of the funds provided in carrying out a portion of the programmatic effort under a sponsored project.
A "sub-award" is an award of financial support by Teachers 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 sub-recipients.
Responsible Office: Grants and Contracts Accounting Office
Effective Date: May 15, 2020