Subrecipient Monitoring Presented by the HMS Subrecipient Monitoring Committee 04/14/2017

Membership/Structure Current Members: SPA: Melissa Maher, Susan Cohn-Child, Sivan Ehrlich Research Finance: Rita Bergemann Academic & Research Integrity: Amanda Humphrey Department: Monica Ruse, Steven Dawson, Sunny Alvear, Ryan Hanna http://hlcra.harvard.edu/subrecipient-monitoring

Why Subrecipient Monitoring? Uniform Guidance: Requires prime recipients of federal funds (“pass-through entities”) to evaluate each subrecipient's risk of noncompliance in order to determine the appropriate monitoring level, monitor the activities of subrecipients to ensure compliance with applicable Federal statutes and regulations and terms of the subaward, and verify that subrecipients are audited as required by Subpart F of the UG Non-federal subs: Monitoring of subs is still required by Harvard’s Subrecipient Monitoring policy, may be required by sponsor; ensure good stewardship of sponsored funding

Policy and Toolkit New policy will be published on the OSP website. Changes to clarify roles & responsibilities, primarily the risk assessment of the individual organization Toolkit has been updated from earlier version and includes: Sample invoices with rollovers Invoice checklist PI Questionnaire Invoice PI attestations, electronic signature instructions Special considerations for foreign subs

Risk Assessment Database New subrecipient Organization database is available to everyone with an HUID Each organization is assessed annually by OSP and assigned a risk level of Green, Yellow, or Red Guidance document for using the database will be part of the Toolkit https://hu.sharepoint.com/sites/ca/vpf/Office_Sponsored_Programs/Sub_Mon_Database/SitePages/Home.aspx Mention that the database is updated based on Quarterly Reports

SPA Outgoing Subs Process New risk assessment steps (supplements reports) No additional requirements for departments, except responding to SPA’s questions: Any concerns or additional info re: assessed risk? For amendments, any issues with subaward? HLCRA Business Process Page for HMS/HSDM (Outgoing Subawards Process): http://hlcra.harvard.edu/hmshsdm-business-processes Process is for SPA’s internal use, but shared to give others insight and information

Sign up available on the Harvard Training Portal Upcoming Training Mark your calendars! Subrecipient monitoring joint training sessions with School of Public Health June 8 and June 13, 2017 10:00am-12:00pm Sign up available on the Harvard Training Portal Mention what kind of information will be covered in the training?

Contact Us Questions, Concerns, Suggestions? Contact the HMS SMC at: HMS_Submonitoring@hms.harvard.edu Thank you!