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Appendix A: Subrecipient versus vendor determination
College Hall 108
Policy statement and procedures Adopted August 2008
The University will follow the requirements of the Office of Management and Budget (OMB) the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, known as the Uniform Guidance or 2 CFR 200 and other applicable federal regulations with respect to monitoring its subrecipients of federal awards.
The University is accountable for responsibly entering into research subcontracts and for appropriately monitoring those subrecipients. For subrecipients who expend $500,000 or more per year of federal awards, the University will also comply with the audit requirements of Single Audit (formerly A-133). There are specific financial and administrative regulations governing the management of federal grants and contracts. As such, subrecipients with whom the University contracts to work on federal grants and contracts are also governed by the same regulations. Penalties for noncompliance include adverse audit findings, financial liabilities on current and past awards and loss of eligibility to receive future awards.
A subagreement may be either a subcontract or a subgrant, each of which is an agreement between the University and a third party, to transfer a portion of the University’s obligations on a sponsored project to that party. The third party in these cases is also known as a subrecipient.
A simple vendor of goods or services differs from a subrecipient in several ways. See Appendix A for help determining if a third party is a vendor or a subrecipient. This policy does not apply vendor relationships. The University will use the following procedures for its subrecipient compliance:
Subrecipient Contract Creation
Subrecipient Contract Monitoring
The PI is responsible for monitoring the subcontractor’s post-award performance and costs. The PI must monitor the subrecipients to ensure that performance goals are achieved and, to the extent possible, that they are administering the federal awards in compliance with laws, regulations and the provisions of contracts or grant agreements.
The PI is also responsible for obtaining invoices from the subcontractors per the timelines established in the contract. The PI must review all invoices from subcontractors and attest that performance is satisfactory and on schedule prior to the University making payment. Invoices from for-profit subcontractors must identify the names and titles of all persons for whom direct labor is charged. The PI must note his/her approval by signing the invoice.
The Finance Office will work closely with the PI to ensure that invoices are charged to the appropriate contract. On a quarterly basis, the grant accountant will send the PI a schedule of payments made on the existing contracts. The PI and grant accountant will determine a plan to address delinquent bills.
Before final payment is made, PIs must certify that the sub-recipient has provided Gallaudet University everything necessary to meet sponsor requirements for formal closeout. For example (as may be applicable) the PI will compile the sub-recipient’s final report, invoice, property inventory report and patent disclosure statement; sub-recipient’s release; sub-recipient’s assignment of refunds, rebates, credits and other amounts; and sub-recipient’s certification of compliance with the audit requirements as required by 2 CFR 200, “Single Audit”, (Formerly A-133 or A-128 Audits).
Subrecipient Contract Maintenance
If the PI decides to renew the sub-recipient agreement, the Subrecipient Contract questionnaire must be completed again. The same process as above holds, with the addition that the controller must also sign the request. The controller indicates that sub-recipient auditing (see below) was conducted by signing the questionnaire, and the sub-recipient has been cleared for contract renewal.
The Finance Office will monitor sub-recipients through their Single Audit report certification. On an annual basis, the Finance Office will request copies of the Single Audit report certification from each sub-recipient.
Origination date: August 2008 Last amended date: May 2020Next review date:
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