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

2. 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

3. 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

4. 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

5. 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
Mention that the database is updated based on Quarterly Reports

6. 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):
Process is for SPA’s internal use, but shared to give others insight and information

7. 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?

8. Contact Us
Questions, Concerns, Suggestions? Contact the HMS SMC at: Thank you!