Subrecipient Monitoring

1. Subrecipient Monitoring December 7, 2007 Office of Research Services Brown Bag

2. Old Requirement but New Emphasis • A-110 Requirement • Grant recipient must monitor each program, function or activity funded with federal dollars including subawards • A-133 Requirement • Monitor activities of subrecipients as necessary to ensure that federal awards are used for authorized purposes and … that performance goals are achieved

3. University Policy • SPP 2131 • Compliance with Subrecipient Standards of OMB Circular A-133 • SPP 2135 • Monitoring Subrecipients Not Subject to OMB Circular A-133 • Policies define responsibilities

4. Why Now? • Increase in A-133 threshold decreases number of subrecipients covered by single audits • Included in Penn’s A-133 audit • Increased scrutiny of all grant activities • False Claim Act and Qui Tam Cases • 10 fold increase since 1986

5. Recent OIG Audits • University of Massachusetts Medical School • Subawards to Yale and Roger Williams Hospital • Refund to NIH totaling $249,525 • Dartmouth College • $716,522 in subaward costs were questioned due to lack of procedures and documentation related subrecipient monitoring

6. Who is Responsible? • Principal Investigator • Reviews scope of work from subawardee • Certifies that budget is appropriate for scope of work • Approves invoices certifying that the work was completed satisfactorily • Determines additional funding based on progress • Requests reports as needed

7. It Takes a Village • Business Administrator • Collects institutional approvals from subawardee • Send Subaward request Form to ORS • Documents PI approvals of invoices prior to authorizing payment • Reviews invoicing prior to requesting additional funds

8. ORS Workflow Process • Contract Admin/Assoc. Director • Insures complete documentation pkge. • Checks request against NOGA • Forward to subcontract administrator for monitoring • Enters information into activity log for tracking purposes

9. ORS Workflow Process • Subcontract Administrator • Checks if subrecipient is subject to A-133 • If yes, obtains most recent report • If no, requests audited financial statement • Forwards any A-133 reports with significant findings and all non-A-133 financial information to Post-Award Director for review • Checks for debarment/suspension • Prepares and assembles subcontract package

10. ORS Workflow Process • Front Office Staff • Sends completed subcontract via email or hard-copy via UPS • Issues BEN memo when subcontract is fully executed

11. We Heard You • NEED: speed subcontract processing time without compromising compliance • Eliminated requests for duplicate documentation • ORS now responsible to secure F&A rate agreements • Sending subcontracts out unsigned pending receipt of regulatory documents • Emailing subcontracts instead of hard-copy UPS whenever possible • Accepting emailed subcontracts from subrecipient • Issuing unilateral modifications where appropriate

12. Next Steps • Communicating with our Peer Institutions about Best Practices • Participating in FDP A-133 pilot • Panel Discussion planned for Winter 2008