To establish responsibility for monitoring subrecipients receiving federal funds but not subject to the Office of Management and Budget’s (OMB) Uniform Guidance single audit or program-specific audit (2 C.F.R. Part 200.501)
May 2021Responsible Office
Subrecipients not subject to OMB Uniform Guidance Audit are defined as for-profit and those non-profit organizations not meeting the federal expenditure threshold of $750,000 per annum, as well as all foreign institutions or organizations.
Prior to submitting a University proposal to a Federal sponsor that includes the above defined subrecipient, the Office of Research Services will ensure that the subrecipient has supplied the University with a letter of intent signed by an authorized institutional official or, in the case of proposals to Federal sponsors that utilize the Grants.gov portal for submission, a completed and signed SF424 cover page, scope of work, budget, and F&A Cost Rate Agreement if applicable. If no F & A Cost Rate Agreement exists, a deminimus rate of 10% will be used for the budget.
The Office of Research Services, when in receipt of a completed subaward request package, at the time of issuing the subaward, will request and review audited financial statements or the equivalent as determined by the ORS Director of Post-Award and/or in the case of an NIH prime subaward, consult the HHS OIG Corporate Integrity Agreements and Settlement Agreement with Integrity Provisions list.
The Office of Research Services is responsible for administering Federal funds granted to subrecipients. The subaward package will include the following information:
The Office of Research Services will advise the subrecipient of requirements imposed on them by Federal laws, regulations, and the provisions of contracts, grants and cooperative agreements, as well as any supplemental requirements imposed by the University. The following supplemental requirements will typically be imposed irrespective of the amount of the subaward:
In cases where prior experience with the subrecipient or the nature of the organization indicates additional risk, the following conditions may be imposed:
The Principal Investigator is responsible for monitoring the activities of subrecipients, as necessary, to ensure that Federal awards are being used for their authorized purpose and that performance goals are achieved. In doing so, the principal investigator is required to review and approve all technical and financial reports. Principal Investigator concerns regarding the contents of any required report(s) must be brought to the immediate attention of the Office of Research Services.
Principal Investigators must utilize the Office of Research Services Research Inventory System subaward request module found at: https://medley.isc-seo.upenn.edu/researchInventory/jsp/fast2.do to request both an initial subaward agreement and all subsequent modifications to that agreement. The Principal Investigator is required to certify on all subaward and subaward modification requests, that the information on the request form is accurate and that the subrecipient is performing according to the provisions of the subaward agreement.
The Office of Research Services will monitor the subrecipient according to the conditions selected for the subrecipient in Items 4 and 5 above.
If Office of Research Services determines that an audit report includes findings or material non-compliance with federal laws and regulations, they shall notify the Comptroller, and together, they will discuss the findings with the principal investigator and the responsible business administrator to determine an appropriate plan of action which may include adjustment of the University’s records, demand for repayment from the subrecipient, or other remedial action.
Footnotes: Fixed price sub awards require federal awarding agency approval
The source of this document is Research Services.