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Title: Office of Sponsored Programs
Subject: Subrecipient Monitoring                 
Policy No: 2016:02                                                
Applies: University-wide                  
Issuing Authority: Vice President for Research                                          
Responsible Officer:  Vice President for Research                          
Adopted: 04/21/2016
Last Revision: 10/23/2019
Last Reviewed: 10/23/2019

I.      PURPOSE

This policy outlines the University’s responsibility to ensure compliance with OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, including federal agency’s specific Administrative Requirements, Cost Principles, and Audit Requirements, when issuing awards to subrecipients. This policy provides a framework to complete a risk assessment for any subrecipient granted an award where Rowan University is the prime recipient of an award and acting in a pass-through capacity. 

II.     ACCOUNTABILITY

At the direction of the Vice President for Research, the Assistant Vice-President of Research shall implement and ensure compliance with this policy. The Deans, Associate Deans, Department Chairs/Unit heads, Principal Investigators, staff, and departmental staff and administrators are responsible for conducting grant and sponsored projects tasks and duties in adherence with this policy.

III.    APPLICABILITY

This policy applies to all University faculty, employees, staff, students and non-University employees who are stewards of sponsored funds, responsible for supervising and providing oversight related to the subrecipient’s work on the sponsored project, and performs tasks in the completion of day-to-day activities related to grant and sponsored project management and administration.

This policy applies to all federal and state funding sources awarded to or contracted to Rowan University.

IV.    REFERENCES

1. OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards:
   1. (Uniform Guidance) 2 CFR, Subtitle A, Chapter II, Part 200, subparts 330-333, 200.338
   2. 45 CFR 75.350 – 75.353
2. New Jersey State Administrative Code
   1. Title 17. Treasury – General Chapter 12. Div. of Purchase and Property: Procurement Bureau; Contract Compliance and Audit Unit; and Distribution Support Services UnitSubchapter 6. Debarment, Suspension, and Disqualification of a Person(s)
      1. J.A.C. 17:12-6.9
      2. J.A.C. 17:12-6.11

V. POLICY   POLICY

A Subrecipient, as defined by 2 CFR 200;200.93, means a non-federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program, but does not include an individual that is a beneficiary of such program.

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