1. Subrecipient Agreements
CLASP Presentation
January 2018
Jeff Sullivan, Asst Controller ORACS

2. Agenda Required Oversight for Federal Awards DUNS/CFDA
UR Business Process Flow
Roles
Potential Pitfalls
Foreign v Domestic
Public/Private/Single Audit/No Audit/etc.
URFinancials Setup and Processing

3. Required Oversight – Uniform Guidance
A pass-through (Prime) entity must:
Identify the Award and Applicable Requirements (to the Sub)
Evaluate Risk (of the Sub)
Monitor Subrecipient
Ensure Accountability of For-Profit Subrecipients

4. Identify the Award and Applicable Requirements
Notify Sub they are in fact a Sub, including CFDA and FAIN of Prime AWD
What, if any, requirements are imposed upon them via flowthrough
What, if any, additional requirements are imposed from the Prime recipient
Obtain DUNS number from Sub, if applicable

5. Evaluate Risk (of the Sub)
Prior experience w Sub
Results of Sub’s prior audits
Personnel Turnover or System Changes
Extent and Results of Federal awarding agency monitoring, if applicable

6. Monitor Subrecipient
Review Financial and Programmatic Reports, as required
Ensure that any compliance deficiencies identified through audit, on site review, or other means are resolved timely and appropriately
Issue a management decision for audit findings pertaining to the Prime award passed through

7. Ensure Accountability of For-Profit Subrecipients
For-Profit Subs are accountable to the Prime for the use of Federal funds provided
2 CFR 200 Part F is not applicable to For-Profit Subs, therefore the Prime is responsible for establishing requirements, as necessary
The agreement must describe applicable compliance requirements and responsibility

8. DUNS/CFDA
The Data Universal Numbering System, abbreviated as DUNS, is a proprietary system developed and regulated by Dun & Bradstreet (D&B) that assigns a unique numeric identifier, to a single business entity. It was introduced in 1963 to support D&B's credit reporting practice.
The Catalog of Federal Domestic Assistance, abbreviated as CFDA, is a government-wide compendium of Federal programs, projects, services, and activities that provide assistance or benefits to the American public.

9. DUNS/CFDA (con’t)
DUNS allows for tracking of the Sub, disclosure of possible prior sins either via credit report or Single Audit Reporting
CFDA allows a Sub to report on what Federal funds are flowed through their organization, and if necessary, report on
Each reverse disclosure is mandatory under Uniform Guidance

10. UR Business Process Flow
Pre Agreement
PI/Dept
ORPA
ORACS (upon req)
Post Agreement
PI/Dept
ORACS
ORPA (upon req)

11. Pre Agreement Roles PI/Dept ORPA Identify Sub and Qualify Expertise
Determine/conclude reasonable budget
Prepare Request for Subcontract Form
Send Form to ORPA
ORPA
Prepare and Send Sub Profile Form
Complete Risk Assessment Checklist
Conclude on Risk Level of Sub
Execute/Discard Agreement

12. Post Agreement Roles PI/Dept ORACS
Review expenses reported v science performed
Compare actual expense to budget
Ensure expenses are within budget period
Forward to ORACS
Confirm terms or deliverables made prior to FINAL payment
ORACS
Review for PI Approval
Review Accounting Coding (LA,SC)
Review Budget Date
Forward to AP
Obtain Single Audit Certifications Annually
Prepare Single Audit Findings Summary

13. Potential Pitfalls Misdiagnose Risk Keying Errors in Agreement
Keying Errors in Payments (Amt -Budget Date)
Approve excess expenses
Misplaced Invoices
Delinquent Invoices from Sub
Overbilled and Subsequent Return of Funds
Failure to aquire required data

14. Foreign v Domestic Domestic Foreign Many are subject to Single Audit
Ease of Risk Assessment of Audited Fin Stats
Listed in SAM.gov
Foreign
Rarely subject to Award Specific Audit
Currency and Translation Issues
Not listed in SAM.gov

15. Public/Private/Single Audit/No Audit/etc.
Public Co and Private Owned, unlikely to have a Single Audit
Private Owned, unlikely to have a Board of Directors (segregation of duties)
Private Owned and Start Up, unlikely to have Financial and Compliance Experience
Small Non-Profit, usually segregation of duties isssues and lack of financial expertise

16. URFinancials Setup Modified Total Direct Costs – MTDC
$25,000 threshold
Unique Award Line (GR)
Current Federal incremental is 54% or $13,500
Total Direct Costs – TDC
NO threshold
Unique Award Line NOT NEEDED
Usually run at less than Full Rates

17. URFinancials Processing
Subcontract will identify GR510xxx
If agreement is extended we do NOT NEED new GR, unless prime line is void of carryforward.
If a new scope of work, then NEW PO#, and NEW GR and Award Line
If Sub demands NEW PO#, NOT NEW scope of work, then edit existing GR name