Policies & Procedures


 

Section: C&G
Part: PRO
Statement No.: 4.11
Date: 10/01/09
University of North Carolina - General Administration
Administrative Policies and Procedures Manual
Title: Subrecipient Monitoring

   

Before subawards are issued, Sponsored Programs will conduct a risk assessment to determine if the subaward or subrecipient is high, medium or low risk. Risk will be determined through examination of a number of factors including, but not limited to:
 
• Entity status and capacity of the subrecipient or prior history with subrecipient
• Administrative or programmatic complexity of the prime award or subrecipient scope of
   work
• Relation of the prime award to the total current C&G portfolio and relation of the
   subaward to the prime award
• Experience of prime or subrecipient project director
 
Based on the assessment of the representative factors listed above, the subcontract will be given a risk rating of low, medium or high. An appropriation monitoring plan will be implemented based on the risk rating.
 
Low Risk Monitor subrecipient for compliance with programmatic and financial reporting requirements, including confirmation from project director of satisfactory progress at annual increments for multi-year awards prior to issuance of subsequent year amendments.
 
Medium Risk A sample of subrecipient invoice(s) will be selected for further review. Subrecipients will be asked to provide supporting documentation for all expenditures shown on a selected invoice, including appropriate Time and Effort certifications for direct salary expenditures. In the event T/E certification is not complete for the selected invoice at the time of the request, the subrecipient will be required to demonstrate the subject personnel are set-up for time and effort reporting for the period in question. In the event a subrecipient fails to provide adequate documentation in a timely manner, or cannot produce documentation to support expenditures on the selected invoice, the Sponsored Programs Director, the UNC Principal Investigator and the Controller will develop a corrective plan of action. The corrective plan of action may include:
• Required submission of all supporting documentation with each Claim for    
   Reimbursement
• Modification of contract terms and conditions
• Site Visits
 
High Risk A communication plan will be developed in collaboration with the Principal Investigator. The plan will feature a pre-award briefing with the subrecipient project director and appropriate administrative staff and quarterly meetings thereafter, via telephone conference or in-person. Additional monitoring activities or requests for documentation may include:
• Requiring supporting documentation for all expenditures presented on invoices
• Conducting a review of the subrecipient financial management systems to ensure funds
   can be segregated and expenditures attributed to the funds received
• Conducting a review of the subrecipient financial and administrative policies and
   procedures to ensure to determine if adequate internal controls are in place
• Conducting a review of the description of roles/responsibilities of subrecipient project
   director and staff to ensure adequate segregation of duties are in place.
 
For all subrecipients:
 
Prior to issuance of a subaward, the Principal Investigator will provide a justification for the selection of the subrecipient based on eligibility criteria, the capacity/experience to perform the work or other criteria in addition to a justification of the subrecipient’s budget/proposed costs.
Prior to issuance of subawards, all subrecipients will be verified against the State and Federal debarment/suspension lists.
 
At the end of each fiscal year, the Division of Finance will send a letter to each subrecipient, except those subrecipients who are also one of the 16 UNC constituent institutions, requesting certification of compliance with OMB Circular A-133 for the previous fiscal year. The State of North Carolina Single Audit will be reviewed to determine if any of the UNC constituent institutes reported material findings.
 
The Division of Finance will prepare letters using a mail merge function (excel and word) and mail them to the authorizing official identified in contract documents before the end of the fiscal year.
 
The Division of Finance will monitor the distribution of letters for compliance with the requested return date and for disclosure of findings. Responses will be filed in the project folders in Finance.
In the event a subrecipient discloses material findings relative to its UNC subaward or relative to critical business practices that effect all transactions, the Sponsored Programs Director, the UNC Principal Investigator, and the Controller will develop a corrective plan of action. The corrective plan of action may include:
 
•Modification of contract terms and conditions
•Requirements for additional documentation to support claims for reimbursement
•Site visits