Subrecipient Monitoring Policy_v5 jjr042116

ROWAN UNIVERSITY POLICY
Title: Subrecipient Monitoring
Subject: Office of Sponsored Programs
Policy No: OSP: 2016:01
Applies: University-wide
Issuing Authority: Vice President f or Research
Responsible Officer: Directors, Office of Sponsored Programs
Adopted: XX/XX/2014
Last Revision: 04/08/2016
Last Reviewed: 04/08/2016

1. PURPOSE

The purpose of this policy is to outline the University's responsibility for monitoring the programmatic and financial activities of its subrecipients to ensure proper stewardship of sponsor funds.

1. ACCOUNTABILITY

At the direction of the Vice President for Research, the Directors for the Office of Sponsored Programs shall implement and ensure compliance with this policy. The Deans, Associate Deans, Department Chairs/Unit heads, and departmental administrators will comply with this policy.

1. APPLICABILITY

This policy applies to all University employees, graduate students and non-University employees responsible as stewards of sponsored funds.

1. REFERENCES

1. OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ("Uniform Guidance") 2 CFR 200 (http://www.ecfr.gov/cgi-bin/text-idx?tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl ).

1. POLICY

1. Rowan University is responsible for monitoring the programmatic and financial activities of its subrecipients to ensure proper stewardship of sponsor funds. This policy applies to all subawards issued using federal and state funding without regard to the primary source of funding. Additionally, it addresses institutional responsibilities and assists Principal Investigators (PIs) and administrators to ensure that, in addition to achieving performance goals, subrecipients comply with applicable federal laws and regulations and with the provisions of each subaward agreement.   

1. OMB  Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) ("Uniform Guidance"), specifically §200.331, (http://www.ecfr.gov/cgi-bin/retrieveECFR?n=se2.1.200_1331) requires pass-through entities to evaluate each subrecipient's risk in order to determine the appropriate monitoring level, monitor the activities of subrecipient organizations to ensure that the subaward is in compliance with applicable Federal statutes and regulations and terms of the subaward, and verify that subrecipients are audited as required by Subpart F of the Uniform Guidance.  
2. While this policy refers specifically to subrecipient awards issued with federal, federal flow-through funding, or state funds, Rowan may also be required by a nonfederal sponsor to provide evidence of due diligence in reviewing the ability of a subrecipient to properly meet the objectives of the subaward and effectively steward the sponsor's funds. Only in these explicit situations will this policy apply to subrecipients funded with nonfederal monies.
3. Subrecipient monitoring begins at the pre-award stage and ends at closeout. The Office of Sponsored Programs (OSP) will not submit proposals that include subrecipient collaborators without approval from an Authorized Representative of the collaborating organization.

1. When subrecipient monitoring is required by the sponsor, responsibilities are shared among the following:
   1. Principal Investigator (PI)

• Responsible for providing information necessary for the Rowan OSP to contact collaborators' respective OSP offices.
• Monitor documentation of the programmatic progress and ability of the subrecipient to meet objectives of the subaward and alert OSP of potential issues.
  1. Office of Sponsored Programs
• Assess potential subrecipient organizations for programmatic, financial, and administrative suitability at the time of proposal.  
• Request organizational information from respective OSP offices.
• Manage subrecipient monitoring documents.
• Inform departments and PIs when issues are identified with a subrecipient organization with whom they have a proposed or active subaward.
• Confirm the statement of work and review any non-standard terms and conditions of the subaward during the subaward agreement negotiation process.
• Incorporate additional terms into subaward agreements based on information from the PI, subawardee's OSP office, Legal Counsel, and the risk assessment performed of the subrecipient organization.
• Review subrecipient's fiscal health on an annual basis.
• Subrecipient reporting to the federal government and prime sponsors, as required by regulations.
• Assist PIs with issues identified regarding subrecipients' programmatic progress and ability.
  1. Division of Research
• Review high-risk subrecipients with OSP at the proposal stage and determine collaborative suitability.
• Provide oversight to OSP in drafting a Subrecipient Monitoring Plan for high-risk subrecipients.