Subrecipient is the legal entity to which a subagreement is made. Subrecipient is accountable to CU Boulder for the use of the funds provided in carrying out a portion of CU Boulder’s scope of work under a sponsored project (via Federal or non-Federal funding). OUTGOING SUBAGREEMENTS ARE A SIGNIFICANT AREA OF RISK FOR CU BOULDER.
Uniform Guidance 2 CFR 200 Subpart A §200.93 Subrecipient; is a non-federal entity that receives a subaward from a pass-through entity to carry out part of a federal program.
A subagreement can be issued in the form of a subaward or subcontract. A subagreement is issued by CU Boulder, referred to as the prime awardee, to another organization who is responsible for assisting CU Boulder with the scope of work on a sponsored project (either Federal or non-Federal funding).
Uniform Guidance 2 CFR 200 Subpart A §200.92 Subaward; an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal program.
When issuing outgoing subagreements CU Boulder is considered a Pass Through Entity.
Subrecipient monitoring includes those activities undertaken by CU Boulder to review the completion of the scope of work, and financial oversight of the funds that were awarded to the subrecipient.
As the Pass-through entity, CU Boulder must monitor the activities of subrecipients as necessary to ensure that the subagreement:
- is used for authorized purposes;
- is in compliance with Federal statutes and regulations;
- follows the terms and conditions of the subagreement; and
- subagreement performance goals are achieved.
As outlined in the Office of Management and Budget, Uniform Guidance 2 CFR 200 requires that the CU Boulder evaluate the risk of each subrecipient.
Uniform Guidance 2 CFR 200 Subpart D §200.331 Requirements for pass-through entities.
§200.331 (b) Evaluate each sub recipient’s risk of noncompliance
§200.331 (d) Monitor the activities of the subrecipient as necessary
CU Boulder has an ethical responsibility to show we are doing what we can to be good stewards of the Prime Sponsor’s funds.
There are many potential risks if we fail to do Subrecipient Monitoring. Examples of those risks include:
- Negative Audit Findings
- Loss of Existing Awards
- Loss of Future Awards
- Loss of Funds
- Damage to Reputation of Principal investigator and University
It is a collaborative effort at CU Boulder to monitor all outgoing subagreements. There are efforts made in both Central Administration as well as in the departments through the Principal Investigator and their supporting Department Administrator.
In Central Office the Subcontract Officers and Administrators complete:
- System of Award Management (“SAM”) – Domestic
- Visual Compliance - Foreign Entities
- Subrecipient Commitment form or Letter of Intent
- Sole Source Justification (for Prime Procurement Contracts only)
- Sub Review form (captures export control status, special invoicing requirements and deliverables, etc.)
- Cost Price Analysis / Budget Analysis
- Risk Analysis & Checklist
- IRB or IACUC approvals
In the department the Principal Investigator with help from their Department Administrators are responsible for:
- Subrecipient’s burn rate
- Subrecipients’s performance in accordance with statement of work
- Complete and timely deliverables
One of the primary ways in which a Principal Investigator is required to monitor their subs is to review and approve each and every invoice prior to payment. It is important to note that at CU Boulder payment will not be remitted for an invoice until the Department’s Fiscal Manager approves it, which should only be done after receiving Principal Investigator’s approval. All invoices must include:
- Current and Cumulative costs
- Subagreement number
- Purchase Order number
- No Human or Animal charges unless prior approval granted
- Must have CU PI approval
- Final invoice must be marked as such
Each and every subagreement is written with the right to reject an invoice.