Post Award
Research CCHIP #009
CLARIFICATION OR CHANGE IN PROCEDURE (CCHIP)
Subrecipient Monitoring of Sponsored Awards
OVERVIEW
This CCHIP clarifies the activities performed by University of South Florida (“USF”) as a pass-through- entity to monitor and report on a subrecipient’s financial and programmatic performance. The goal of subrecipient monitoring is to review subrecipients periodically to ensure they are in compliance with applicable laws and regulations, as well as the terms and conditions of sponsored projects. These guidelines assist USF in assuring that subagreements are used for authorized purposes and that performance goals are achieved.
DEFINITIONS
Award – Financial assistance and cost-reimbursement contracts that entities receive directly from a sponsoring agency; does not include procurement contracts, under grants or contracts, used to buy goods or services from vendors.
Chartfield – The individual components, or fields, that when combined make up the Chartfield String, which defines the accounting structure.
Pass-Through Entity – An entity that provides a subagreement to a subrecipient to carry out a sponsored project; also known as the recipient of the prime award.
Recipient – An entity that expends awards received directly from a sponsoring agency to carry out a sponsored project.
Sponsored Project – Any grant, contract, or other agreement between the University of South Florida and a sponsoring agency.
Sponsoring Agency – The agency that provides an award directly to the recipient.
Subagreement – Financial assistance and cost-reimbursement contracts that subrecipients receive from pass-through entities; does not include procurement contracts, under grants or contracts, used to buy goods or services from vendors; also known as subgrant if the prime award is a grant (or subcontract if the prime award is a contract).
Subrecipient – An entity that expends awards received from a pass-through entity to carry out a sponsored project; does not include an individual that is a beneficiary of such a program; a subrecipient may also be the recipient of other sponsored projects directly from a sponsoring agency.
Subrecipient Monitoring – Activities performed by the pass-through-entity to ensure that subagreements are used for authorized purposes in compliance with laws, guidelines, and the provisions of the sponsored project and that performance goals are achieved; includes reviewing organizational and financial data in the proposal stage to identify potential risks; annual monitoring post-award may include conducting site visits or performing desk reviews during the conduct of the sponsored project to assess internal controls.
CLARIFICATION OR CHANGE
Subrecipient monitoring and review begins at the proposal preparation stage and continues during the conduct of the sponsored project through closeout. This monitoring and review is a collaborative effort involving various central and programmatic offices.
PROCEDURES
With some sponsors, funds provided for subrecipients may not be used by USF for any other purpose without specific prior written approval from the sponsoring agency. USF will separate the budget for subrecipient costs from other budget awarded by the sponsoring agency through use of the product code within the existing chartfield string.
- Department completes a Grant Budget Release (GBR) form to open the award and establish a budget for the project. The entire subagreement budget within the GBR is assigned a product code of SUB000 (Department indicates the product on the subagreement budget lines — not the top of the form) — no Purchase Orders (POs) should be created using this product code.
- Sponsored Research (SR) will perform a risk assessment to determine the level of exposure to the university; appropriate terms and conditions will be included in the subagreement prior to it being executed fully.
- Sponsored Research Post Award receives the executed subagreement and transfers the budget from the product code SUB000 to the appropriate subcontract product code. (SUB00A, SUB00B, etc.) based on the assigned subagreement number.
- Sponsored Research Post Award assigns the first $25,000 to the appropriate budget account code to be assessed facilities and administrative costs (F&A).
- Sponsored Research Post Award sends an email to the Principal Investigator (PI) and all other appropriate individuals that the subagreement chartfield has been created and the budget has been transferred accordingly.
- Department creates the PO to obligate budget.
- If for any reason a subagreement is not executed, the department will complete a Budget Transfer to return the funds to the primary chartfield (this may require sponsor approval).
EXAMPLE #1
Project ID 1234567890 has one subagreement in the amount of $100,000. This subagreement (1234- 5678-90-A) is completely executed at the time the GBR is being submitted to Sponsored Research Post Award. Complete the subagreement budget on the GBR as follows:
| Budget Account | Product | Initiative | Project |
Activity ID |
Budget |
|---|---|---|---|---|---|
|
83550 |
SUB00A | 0000000 | 1234567890 | BUDGET | 25,000 |
| 83500 | SUB00A | 0000000 | 1234567890 | BUDGET | 75,000 |
EXAMPLE #2
Project 1234567890 has one subagreement in the amount of $100,000. This subagreement (1234-5678- 90-A) is not fully executed and the GBR needs to be submitted to Sponsored Research. Complete the subagreement budget on the GBR as follows:
| Budget Account | Product | Initiative |
Project |
Activity ID |
Budget |
|---|---|---|---|---|---|
| 83550 | SUB000 | 0000000 | 1234567890 | BUDGET | 25,000 |
| 83500 | SUB000 | 0000000 | 1234567890 | BUDGET | 75,000 |
Upon receipt of executed subagreement #1234-5678-90-A, Sponsored Research Post Award will change the product for the subaccount budget to SUB00A.
EXAMPLE #3
Project 1234567890 is non-federal and has one subagreement in the amount of $100,000. This subagreement (1234-5678-90-A) is not fully executed and the GBR needs to be submitted to Sponsored Research Post Award. Complete the subagreement budget on the GBR as follows:
| Budget Account | Product | Initiative | Project |
Activity ID |
Budget |
|---|---|---|---|---|---|
| 82500 | SUB000 | 0000000 | 1234567890 | BUDGET | 100,000.00 |
Upon receipt of executed subagreement #1234-5678-90-A, Sponsored Research Post Award will change the product for the subaccount budget to SUB00A.
Principal Investigator
- Develop budget for subagreement(s) using the appropriate budget chart field string.
- Identify the need for a subagreement(s) and complete required information in the award proposal; if the subrecipient is not identified at the time of the proposal, the subagreement and applicable forms must be completed fully post-award prior to establishment of the subaward.
- Monitor the technical progress of a subrecipient’s performance of obligations as defined in the subagreement.
- Review subrecipient invoices for cost allowability and compliance with federal regulations; prime and subrecipient terms and conditions.
- Resolve financial questions related to invoices including disallowing questionable costs which are not adequately supported.
- Review and approve subrecipient invoices, verifying that billings are consistent with technical/progress reports and production of deliverables (acknowledging special terms and conditions in the subagreement as appropriate).
- Submit invoices for payment in a timely manner and retain copies for departmental records.
Department Administrator
- Responsible for ensuring and collecting all items on the sub recipient checklist.
- Assist PI in developing the budget and chartfield string for subagreement(s).
- Assist PI in developing & implementing a monitoring plan to effectively monitor the performance of obligations as defined in the subagreement(s).
- Monitor expenditures for appropriateness and assist PI with the review of subrecipient invoices for cost allowability and compliance with federal regulations; prime and subrecipient terms and conditions.
- Assist PI with the resolution of any financial questions related to invoices including disallowing questionable costs which are not be adequately supported.
- Assist PI with the review and approval of subrecipient invoices, verifying that billings are consistent with technical/progress reports and production of deliverables (acknowledging special terms and conditions in the subagreement if included).
- Assist with the submission of invoices for payment in a timely manner and retain copies for departmental records.
Sponsored Research Pre Award
- Initiate pre-award subrecipient reviews.
- Review proposal for subagreement(s) to ensure that funds are segregated.
- Consult with University department personnel to perform subrecipient risk assessment for all subrecipients, as deemed necessary.
- Negotiate and execute subagreements between the University and subrecipient organizations, including language requiring adherence to federal regulations and other sponsor requirements as applicable.
- Provide special terms and conditions in the subagreement to manage risk.
- Provide monitoring and guidance in interpreting applicable regulations and subrecipient award terms and conditions, and in executing these procedures.
Sponsored Research Post Award
- Release the project budget for subagreement(s).
- Verify that subagreement(s) chartfield is recorded correctly in the financial system.
- Report subagreement costs accurately to sponsoring agencies on financial reports and invoices.
- Distribute annual Single audit certification request forms and review submitted documentation to assess risk.
- Provide guidance in accordance with the guidelines noted in USF Policy No. 0-302 and the Manual on Managing Sponsored Project Subawards and interpret subrecipient award terms and conditions in executing these procedures.
- Advise PI and department administrators on the proper accounting of subagreement(s).
CONTACT
Please address your comments or questions regarding this CCHIP to Sponsored Research Compliance.
RELATED REFERENCES
Grant Budget Release Form (GBR)
USF Policy No. 0-302
AGENCY GUIDELINES
OMB Circulars (Federal awards issued prior to 12.26.14)
Uniform Guidance (2 CFR §200) (Federal awards issued on or after 12.26.14)
NIH Grants Policy Statement
HHS Grants Policy Statement
NSF Grants Policy Guide
EFFECTIVE DATE
This CCHIP is effective as of the date of revision and rescinds all previous versions pertaining to the Subrecipient Monitoring of Sponsored Projects.
ISSUED: May 20, 2011
LAST REVISION: August 16, 2018