As a prime recipient and a pass through entity of Federal awards, Clark University is required to monitor the activities of sub-recipients. In order meet the requirements of the Office of Management and Budget (OMB) Circular A-133 (Audits of States, Local Governments, and Non-Profit Organizations), the University shall perform the following with respect to sub-recipients/sub-awards:
- Identify Federal awards made by informing each sub-recipient of CFDA title and number, award name and number, award year, if the award is R&D, and name of Federal agency. If any of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award.
- Advise sub-recipient of requirements imposed on them by Federal laws, regulations, and the provisions of contracts or grant agreements as well as any supplemental requirements imposed by the pass-through entity.
- Monitor the activities of sub-recipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grants agreements and that the performance goals are achieved.
- Ensure that sub-recipients expending $500,000 or more in Federal awards during the sub-recipient’s fiscal year have met the audit requirements of OMB A-133 for that fiscal year.
- Issue a management decision on audit findings within six months after receipt of the sub-recipient’s audit report and ensure that the sub-recipient takes appropriate and timely corrective action.
- Consider whether sub-recipient audits necessitate adjustment of the pass-through entity’s own records.
- Require each sub-recipient to permit the pass-through entity and auditors to have access to the records and financial statements as necessary for the pass-through entity to comply with this part.
Post Award Sub-Recipient/Sub-Award Monitoring
The Principal Investigator (PI) is responsible for monitoring the activities of the sub-recipient. The sub-recipient should submit progress reports, technical reports and other deliverables to the PI by specified due dates. The PI is responsible for forwarding copies of the sub-recipient’s progress report and/or technical report(s) to the Office of Sponsored Programs and Research (OSPR).
Sub-recipient invoices submitted to the University must contain the following information:
- Invoice must be on the sub-recipient’s letterhead
- Date of invoice
- Invoice number
- Period of performance covered by the invoice
- Itemized description of services and backup documentation
- Current period costs, including cost sharing
- Cumulative projects costs, including cost sharing
- Sub-recipient contact person with respect to invoice
- Invoice must be signed by an authorized official of the sub-recipient
- Invoice must contain a certification that all payments requested are for appropriate purposes and in accordance with the agreements set forth in the application and award documents
The PI is also responsible for reviewing and approving invoices from sub-recipient(s) for adherence to the budget. The signature of the PI on the invoice indicates that the review has taken place and that the invoice adheres to the budget.
Grants Accounting will review the sub-recipient’s invoice(s) for the following:
- Period of performance is within the contract period
- Appropriate invoice format and level of detail
- Signatures of the PI
- Certification or signature by authorized sub-recipient representatives
- Funds are available in contract
- Cost Share documentation, if applicable
Grants Accounting is responsible for ensuring that sub-recipients that expend $500,000 or more of federal funds each fiscal year submit an A-133 Audit Certification Letter.
Sub-recipient award closeout requirements:
- Receipt of final invoice
- Receipt of Cost Share documentation, if applicable
- Time and Effort certifications
- Final progress and technical reports
- Annual A-133 certification letter