SUBRECIPIENT MONITORING POLICY

 

ORIGINATOR: Business and Finance

DATE: May, 2003 (revised)

POLICY #99-1

 

I. PURPOSE

Federal regulations require pass-through entities to monitor subrecipients. The purpose of this policy is to provide guidance to University staff in monitoring subrecipients to ensure their compliance with federal laws and regulations.

II. DEFINITIONS

PASS-THROUGH ENTITY: An OMB Circular A-133 term for a nonfederal entity that provides a federal award to a subrecipient to carry out a federal program.

SUBRECIPIENT: A subrecipient is defined by OMB Circular A-133 as a Non-federal entity that expends federal awards received from a pass-through entity to carry out a Federal program, but does not include an individual that is a beneficiary of such a program. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency.

RECIPIENT: A recipient means a non-Federal entity that expends federal awards received directly from a federal awarding agency to carry out a federal program.

III. APPLICABILITY

This policy applies to subrecipients of the University of Rhode Island as distinct from vendors of the University of Rhode Island.

A subrecipient is characterized as an entity that

A vendor is characterized as an entity that

IV. MONITORING REQUIREMENTS AND PROCEDURES

Whenever a subrecipient relationship exists, the University at the primary recipient must monitor the subrecipient to ensure its compliance with federal laws and regulations. The monitoring responsibilities at the University are as follows:

A. The Research Office's responsibilities for subrecipient monitoring shall include the following:

B. The principal investigator (or his/her designee) responsibilities for monitoring subrecipients shall include the following:

C. The Office of the Controller, in compliance with Circular A-133, and to establish controls in relation to the University's subrecipient's expenditures, will perform the following monitoring requirements: