Contracts and Grants Sub-recipient Monitoring

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Policy Code: 
4149
Approval Authority: 
Vice Chancellor
Policy Type: 
Divisional Policy
Policy Owner: 
Administration and Finance
Responsible Office: 
Administration and Finance - 828.251.6742

I. Purpose

This policy provides University guidance for complying with OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Requirements), specifically with respect to its regulations addressing oversight of subrecipients on sponsored programs.

II. Scope

This policy applies to all sub-awards issued under sponsored awards made to the University of North Carolina at Asheville (UNC Asheville) without regard to the primary source of funding. Contractor (Vendor) agreements no subject to this policy.

III. Policy

UNC Asheville monitors the programmatic, administrative and financial activities of its sub-recipients in order to ensure proper stewardship of sponsor funds. This policy sets forth guidance to assist the University in ensuring that sub-recipients conduct their portion of the project in compliance with applicable laws, regulations, and terms and conditions of the award and that project costs incurred by sub-recipients are reasonable and allowable.

IV. Definitions

Contractor (Vendor) – an entity receiving a portion of funds from the grant if it:

  •     provides the goods and services the project requires within their normal business operations;
  •     provides similar goods or services to many different purchasers (this includes fabrication of new goods, consultants, editors, etc.);
  •     operates in a competitive environment (a for-profit organization or an entity/university providing testing services);
  •     is not subject to terms and conditions/compliance of the sponsoring agency (however this is not always the case: some sponsors require that obligations and compliance requirements in the terms and conditions of the prime agreement be flowed down to any lower-tier recipient; the rights granted to UNC Asheville by the sponsor, however would not be flowed down, as procurement is considered work for hire and anything produced by the contractor is owned by UNC Asheville); and
  •    is not involved in the programmatic work of the project, including project deliverables or technical report.

Principal Investigator / Project Director (PI/PD) – the individual responsible for the development, writing, and conduct of a sponsored award, who also has primary responsibility for the technical and fiscal management of the award.

Sponsored Programs – projects and/or activities which are originated and conducted by members of the faculty or, in some instances, by staff members. Such programs are supported wholly or in part by external restricted funds awarded to the University by an external sponsor.

Sub-award – award of financial assistance from a prime awardee to a qualified organization, for the performance of a substantive portion of the programmatic effort under a sponsored project.

Sub-recipient – an entity receiving a portion of the funds from a sponsored award and having programmatic involvement in the project if:

  •     has programmatic involvement in the project identified as a separate scope of work, with separate budget and organizational approval;
  •     has its performance measured against whether the objectives of the project are met;
  •     has responsibility for programmatic decision-making;
  •     has responsibility for adherence to applicable program compliance requirements;
  •     uses the sponsored funds to carry out a program at their organization as compared to providing goods or services for a program at UNCA;
  •     has responsibility responsibility for assisting in completion of the project deliverable and/or technical report;
  •     has the right to publish project results or serve as a co-author (the rights and obligations stated in the prime grant terms and conditions generally are flowed down to the subrecipient); and
  •     has the option to develop patentable technology.

V. Procedure

    A. Pre-Award Administration

    1. Principal Investigator / Project Director Responsibilities

        a. Identify all sub-recipients and contractors to the sponsor within the proposal.

        b. From contractors, acquire the following documents as part of the proposal review process:

  •   sub-recipient scope of work;
  •   sub-recipient line item budget with justification;
  •   completed sub-recipient commitment form; and
  •   other documents as requested by the research administration.

    2. Office of Sponsored Scholarship and Programs (OSSP) Responsibilities

        a. Review scope of work, budget documents, and sub-recipient commitment form for compliance with the Uniform Requirements.

        b. Determine the proposed relationship – sub-recipient versus contractor.

        c. Check sub-recipient against compliance databases.

  •   North Carolina Suspension of Funding List;
  •   eCustoms Visual Compliance; and
  •   Federal System for Awards Management.

        d. Conduct a risk analysis of sub-recipient.

        e. Coordinate information requests with the PI and sub-recipient.

    B. Post Award Administration

   1. OSSP Responsibilities

        a. Check sub-recipient against compliance databases.

  •   North Carolina Suspension of Funding List;
  •   eCustoms Visual Compliance; and
  •   Federal System for Awards Management

        b. Review risk analysis and adjust based on new findings. 

        c. Contact sub-recipient to request confirmation of information on the sub-recipient commitment form.

        d. Coordinate contract development with PI/PD.

        e. Generate sub-recipient contract.

        f. Coordinate with Sponsored Programs Accountant (SHRA) to resolve concerns over sub-recipient compliance and risk.

        g. Provide agreement and FCOI certification to the sub-recipient for review and endorsement.

        h. Negotiate terms and conditions of the agreement with the sub-recipient.

        i. Upon execution of agreement, turn over all documents associated with sub-recipient to SHRA.

    2. PI/PD Responsibilities

        a. Review the sub-recipient contract for accuracy in scope of work and budget.

        b. Notify the OSSP of any changes in sub-recipient status, scope of work, and budget.

        c. Notify the OSSP of any changes to the sub-award that may generate a modification or termination of the original sub-recipient agreement.

        d. Review technical performance reports, or other specific deliverables a timely basis. Any unforeseen issues should be documented, investigated, and resolved.

        e. Obtain required deliverables including the technical/progress reports, patent invention documentation and equipment reports from the sub-recipient.

        f. Review all technical/financial reports to ensure the sub-recipient provided all project deliverables and met project objectives.

    3. SHRA Responsibilities

        a. Review sub-recipient packet provided by OSSP.

        b. Conduct ongoing monitoring of sub-recipient risk.

        c. Coordinate sub-recipient risk management with OSSP and PI/PD.

        d. Review sub-recipient invoices for appropriateness of expenditures.

        e. Notify PI/PD of changes in sub-recipient status, invoicing and risk.

        f. Communicate with sub-recipient regarding close out of agreement.

        g. Maintain a separate sub-recipient management file for each agreement.

        h. Report findings of non-compliance to the sponsor and appropriate State entities according to University policy and procedures.