Risk Assessment and Subrecipient

Monitoring

Portia Garvey, Assistant Director, Preaward Services

Research Office

Research 0

Research

Risk Assessment and Subrecipient

Monitoring

Learning Objectives

• Understand Importance – the “WHAT” and “WHY” behind subaward

risk assessments and subaward monitoring

• Understand Considerations and Appropriate Approaches to

Effectively Monitor Subawards Activity

• Discuss Roles and Responsibilities Critical to Success

• Overview of Subaward Invoicing Process

• Leave with Valuable Tips and Recommendations to Avoid Issues

and Delays During the Life of the Award and Close-Out

Research 2

What is Risk Assessments/Subrecipient

Monitoring??

The process of providing oversight on subawards throughout the

lifecycle, including:

• Obtaining appropriate information in support of your proposal

• Reviewing appropriateness of the subawardee

• Determining risk associated with a subawardee

• Monitoring activities during the period of performance of the

subaward

Research 3

What about Uniform Guidance??

• States that pass-through entities must “monitor the activities of

subrecipients as necessary to ensure that Federal awards are used

for authorized purposes in compliance with laws, regulations, and

the provisions of contracts or grant agreements and that

performance goals are achieved”.

• The Uniform Guidance replaces the term “Federal awards” with the

term “subaward,” clarifying that pass-through entities are primarily

responsible for evaluating and monitoring subrecipient institutions

on awards for which they are directly accountable. That said, pass-

through entities do need to verify (as opposed to ensure) that

subrecipients are audited in accordance with the Uniform Guidance.

Research 4

Proposal Preparation

• Deciding at the proposal time if you are working with a sub,

consultant or vendor

• Not always obvious

• Do your homework

• Share chart with PI to help determine

• http://www.udel.edu/research/pdf/sub-v-consult.pdf

Research 5

Award Notification

• Received award notification

• Subaward has been included in the budget

• Let the risk assessment begin!!!

Research 6

When does Subaward Risk Assessment

Occur?

• Receipt of award – identification of subaward in budget

• Department initiates requisition for subaward

• RO initiates risk assessment documentation

• Risk assessment includes series of questions specific to

subawardee (most information pulled from subrecipient commitment

form)****

– ***Delays may occur if appropriate paperwork and subrecipient

commitment form was not obtained at proposal time

College or Department name here 7

What Determines Risk

• Risk Assessment includes series of questions – some questions

with specific scoring

• Questions resulting in a score of 3 automatically identifies

assessment as “high risk” category

• High risk subawards are reviewed by RO management team

• In high risk instances, RO will contact PI/department administrator

• Recommendations will be provided to decrease/address risk areas

or preventative terms/conditions may be included in the subaward

• High risk category does not necessarily equate to not working

with the subawardee

College or Department name here 8

• Foreign Sub

• Delays in Invoicing/Issues with Invoicing

• A-133 Audit Findings or No A-133 Done

• No A-133 may require mini audit questionnaire

• Other (Less than 1 Year in Operation, Significant Amt of $ to Sub)

Research 9

High Risk Factors

Risk Assessment Completed

• Based on assessment of subawardee, RO may include special

language to be added to subaward (reviewed/acceptable by PI)

• Possible language

– Additional financial reporting

– Request for receipts at various invoicing intervals

– Release of partial funding vs. full year funding

– Include site audits

– Monthly or quarterly calls with subawardee – programmatic

review

College or Department name here 10

Risk Assessment Completed

• Risk assessments are filed in RO; processed for each new

subaward

• Documentation utilized to support KMPG annual audit

College or Department name here 11

Subaward Package Assembled

• RO prepares documentation for submission to sub

• Based on assessment, if sub is high risk, may add special

requirements (reporting, auditing, special reviews, milestones)

• Obtains approval from PI

• RO executes subaward documentation

Research 12

Monitoring Considerations During Cycle of

Subaward

• Are invoices received timely – critical to good award management

• Carryover considerations (large carry over amounts)

• Performance vs. Spending (program calls with PIs)

• If during the cycle of the award the above are identified as issues,

consider add special terms as a monitoring mechanism (reporting,

auditing, special reviews, milestones or other)

• Discuss with PI

Research 13

Invoicing

• Invoices must be submitted by subawardee to subaward

email inbox for payment (subaward-invoices@udel.edu)

– No paper copies being accepted

– No email copies accepted unless the subawardee

submits the invoice directly to the subaward inbox

email

Research 14

Invoicing/Payment

• Invoice webform is initiated by the RO invoicing coordinator (initial

review to ensure mandatory info letterhead, certification, PO)

• No longer using email approval

• Electronic approvals include department, PI, and RO (others as

necessary)

• Procurement issues payment – once RO C/G does final approval of

invoice (typically paid each Wednesday)

College or Department name here 15

Invoicing/Payment

What happens when?

• Delay in invoicing or no invoices until end

– Department award management/monthly review of award and

expenses should identify this

– Depending on relationship with subawardee, either RO can

reach out or department can reach out to subaward

– Determine the cause or problem/delay

– Issue with delay in invoicing – may overstate funds causing

issue through life of award

– Can cause issue at close-out as well

College or Department name here 16

Subaward Monitoring Checklist

• Provides a consistent approach to review of invoices

• Low volume of subawards

• Training tool for others in department

College or Department name here 17

Subaward Monitoring

Checklist

- Each invoice needs to be

checked for accuracy!

- Use this checklist for each

invoice to check for compliance

- http://www.udel.edu/research/pd

f/training/subaward-monitoring-

checklist.pdf

Research 18

Questions to Consider

During Review of Invoices

• Is the subrecipient’s work progressing according to

schedule?

• Are deliverables and reports being provided on time or in

a timely manner?

• Are all compliance considerations up-to-date?

• Are funds being spent according to the budget and within

the project timelines?

• Does cumulative invoice amount align?

Research 19

Keeping on Track!

• Keep track of sub spending and invoice payments on UDataGlance

• UData will keep track of PO’s as an obligation

• Query can be used to view what has been committed and expended

for purchase order by PS Account.

- GMQ_PO_ACTIVITY_SUM

Research 20

SUMMARY

• Why Subrecipient Monitoring is Important

– Questions to Ask

• Risk Assessment

– How it Works

– Benefits

• Electronic Subaward Invoice Process

– Monitoring Checklist

Research 21

TAKE AWAY

We All Play a Role in the Process

College or Department name here 22

QUESTIONS

??

Research 23

Research 24