Agency Roundtable Discussion: Subrecipient Monitoring

2

Data to Communicate to Subrecipients

• Subrecipient name (must match registered name in DUNS)• Subrecipient DUNS number (can be found on Sam.gov)• Federal Award Identification Number (FAIN)• Federal award date• Subaward period of performance start and end date• Amount of Federal funds obligated by this action• Amount of Federal funds obligated to the subrecipient• Total amount of the Federal award• Federal award project description, as required to be responded to the Federal Funded

Accountability and Transparency Act (FFATA)• Name of Federal awarding agency, pass through entity, and contact information for

awarding official• CFDA number and program name • Whether or not the award is R & D (Research & Development)• Indirect cost rate for the Federal award

3

Data to Communicate to Subrecipients

Additionally the subaward must include: • All requirements imposed by the pass-through entity so that the Federal

award is used in accordance with Federal statutes, regulations and terms and conditions of the Federal award.

• Any additional requirements including identification of any required financial and performance reports.

• A negotiated indirect cost rate between the subrecipient and the Federal government. If no such rate exists, a rate negotiated between the pass-through entity or the subrecipient or the De minimus rate of 10%.

• A requirement that the subrecipient provide access to its records and financial statements.

• Appropriate terms and conditions regarding the closeout of the subaward.

4

Subrecipient Risk Assessment

Pass-through entities must evaluate each subrecipient’s risk of non-compliance with Federal statutes, regulations, and terms. The risk assessment factors may include:

• Subrecipient’s prior experience with the same or similar award

• Results of previous audits• Whether or not the subrecipient receives its own Single

Audit and if the subaward has been audited as a major program

• Subrecipient has new personnel or systems• Extent and results of Federal awarding agency monitoring

5

Subrecipient Monitoring Plan

Pass-through entities must monitor the activity of the subrecipient in order to ensure the subaward is used for authorized purposes, is in compliance with Federal regulations, and that performance goals have been achieved. The monitoring plan must include:• The review of financial and programmatic reports• Ensuring the subrecipient takes timely and appropriate

actions on deficiencies pertaining to the award.• The issuance of management decisions for audit

findings pertaining to the award.

6

Subrecipient Monitoring Plan

The following monitoring tools may be useful to ensure proper accountability and compliance:• Providing subrecipients with training and technical

assistance in relation to specific programs• Performing on-site reviews of the subrecipient’s

program operations• Arranging for agreed-upon procedures

engagements as described in 200.425 Audit Services

7

Key Points to Remember Risk assessments should be conducted periodically. We recommend at award

date and annually thereafter. Any risk assessment or monitoring that is done must be documented. Monitoring does not have to be the same for every subrecipient. For example,

more monitoring should be done for a higher risk subrecipient than for one who is determined to be lower risk.

Requiring invoices is considered a part of monitoring, but should not be the only monitoring that is done.

Subrecipient training should not be overlooked as a part of monitoring. Agencies can provide training to other agencies as well as subrecipients.

If Conducting an on-site audit as part of monitoring, remember the following: All aspects of the audit should be documented, including when visited, who you talked

to, and what was tested. The audit does not have to be limited to compliance. Controls can also be tested,

especially if the control structure is thought to be weak.

8

Discussion Question #1

How does your agency evaluate risks for subrecipients?

9

Discussion Question #2

What type of subrecipient monitoring does your agency do to ensure compliance?

10

Discussion Question #3

What issues has your agency faced regarding subrecipient monitoring? How did those issues

get resolved?

11

Other Questions or Concerns?