9.6 Subrecipient Monitoring in Grant-Sponsored Programs Policy

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Chapter 9: Grants and Sponsored Projects

9.6 Subrecipient Monitoring in Grant-Sponsored Programs Policy

Related Policy from the Code of Federal Relations: 2 CFR 200.93 (http://www.ecfr.gov/cgi-bin/text-idx?node=2: and 2 CFR 200.330-332 (http://www.ecfr.gov/cgi-bin/text-idx?node=2:

Purpose:  The purpose of the subrecipient monitoring policy is to ensure that Normandale Community College complies with the Federal laws and regulations and the provisions of agreements concerning subrecipients on any Federal awards.
Normandale is responsible for monitoring the programmatic and financial activities of any subrecipients of grant funds in order to ensure appropriate stewardship of those funds. This policy addresses Normandale’s responsibilities and assists Principal Investigators (PI), Project Directors (PD), and staff to ensure that subrecipients comply with Federal laws and regulations and the provisions of any agreements that govern the subaward in addition to achieving performance goals.

Part 1: Definitions

Subaward: An award provided by Normandale Community College as the pass-through entity to a subrecipient in order for the subrecipient to carry out part of a Federal award received by Normandale (2 CFR 200.92).

Subrecipient: A non-Federal entity that receives a subaward from Normandale as the pass-through entity to carry out part of a Federal program (2 CFR 200.93). Typically, a subrecipient meets the majority or all of the following criteria:

   • Has responsibility for determining who is eligible to receive what Federal assistance;
   • Has its performance measured in relation to whether the objectives of the Federal program/award were met;
   • Has responsibility for programmatic decision-making;
   • Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and
   • In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to
      providing goods or services for the benefit of the pass-through entity (2 CFR 200. 330)

Contractor: An individual or entity that provides goods and services for the primary awardee, which enters into a procurement relationship with the contractor. Characteristics of a contractor are:

   • It provides the goods and services within normal business operations;
   • It provides similar goods or services to many different purchasers;
   • It normally operates in a competitive environment;
   • It provides goods or services that are ancillary to the operation of the Federal program; and
   • It is not subject to compliance requirements of the Federal program as a result of the agreement, though similar requirements may apply for other 

Principal Investigator (PI) or Project Director (PD): The individual with the primary responsibility for monitoring subrecipients’ progress and ensuring compliance with Federal regulations of the primary awardee (Normandale) and subrecipient award terms and conditions.

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Part 2: Responsibilities

Grants & Sponsored Projects Office: Normandale must ensure that its subrecipients comply with the Uniform Guidance requirements, cost principles, and audit requirements. Specific responsibilities of the Grants Office and its designees (including PIs and PDs) include:

  1. Determining whether a non-Federal entity is a subrecipient or a contractor.
  2. Ensuring that every subaward is clearly identified to the subrecipient as a subaward.
  3. Informing the subrecipient of all applicable federal laws and regulations governing the agreement, as well as any additional requirements Normandale imposes in order to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports.
  4. Evaluating subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining appropriate subrecipient monitoring.
  5. Establishing appropriate terms and conditions regarding closeout of the subaward.
  6. Monitoring the performance and activities of the subrecipient to ensure that the subaward is used for authorized purposes, in compliance with Federal laws and regulations, and that performance goals are achieved.
  7. Making sure that all costs of the subaward are in accordance with the cost principles and procedures applicable to the award agreement (necessary, reasonable, allocable, and allowable).
  8. Verify that subrecipient is audited when it is expected that the subrecipient’s Federal awards expended during the fiscal year will equal or exceed the threshold set in §200.501 Audit requirements.

Principal Investigator (PI), Project Director (PD), or designee. The PI/PD is responsible for monitoring subrecipient performance by reviewing technical performance reports or other specified deliverables on a timely basis. Monitoring may include on-site visits to evaluate compliance with regulations and award terms, including status of performance and deliverables. Along with the Fiscal Services Office, the PI/PD is responsible for reviewing subrecipient invoices, identifying and following up on questionable expenditures, and maintaining documentation of monitoring efforts.

Fiscal Services. The Fiscal Services Office will provide the PI/PD with expense to budget comparisons to assist with financial monitoring. The Fiscal Services Office will assist PIs/PDs with identifying questionable expenditures and requesting clarification and/or documentation of invoiced charges that appear unusual, excessive, or otherwise questionable.

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  Policy History:
Date of Adoption:  4/02/2019
Department / Owner: Grants
Date and Subject of Revisions:
Next Review Date:  4/02/2023
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