1. Subrecipient Monitoring
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Presented by the HMS Subrecipient Monitoring Committee
04/11/2018

2. Membership/Structure
Founded in April 2014
Current Members:
Chair: Melissa Maher, Manager, Subawards, HMS Office of Research Administration (ORA)
ORA: Susan Cohn-Child, Sivan Ehrlich
ORA Research Finance: Rita Bergemann, Mark O’Brien
Academic & Research Integrity: Suzanne Higgins, Samantha Speyer
Department: Monica Ruse, Steven Dawson, Sunny Alvear, John Serpico, Victoria Nguyen

3. Subaward Statistics Harvard Schools with subagreements:
How does HMS compare? As of January 2018:

4. 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

5. Risk Assessment Database: GMAS Transition
Each subrecipient organization is assessed annually - or every 3 years for Single Audit entities - by OSP and assigned a risk level of Green (low-risk), Yellow (medium-risk or insufficient data), or Red (high-risk)
The GMAS Organization page will now contain the risk assessment information that was available in the database, except for quarterly comments
Same permissions will apply – Assessors (OSP + “HEAT” Harvard extended assessment team) will have access to edit, while other GMAS users will have view access
Can also see current awards with a subrecipient institution across Harvard from the Organization page; ability to drill down into records dependent on your permissions
Note: See REACH slides for questions on risk assessment process.

6. Subs Process – Emails to Dept.
ORA’s process for drafting a new subaward or amendment includes sending an to department to review for accuracy (correct dates, dollars, etc.)
We recently updated the template we use (regular and DocuSign) when sending drafts to departments for review, to clarify roles and responsibilities

7. Subs Process – Emails to Dept.

8. ORA Outgoing Subs Process
OSP and ORA are responsible for risk assessments and checking a subrecipient’s risk level when issuing and award
Departments can check risk assessments and comments in GMAS but are NOT required to do so
HLCRA Business Process Page for HMS (Outgoing Subawards Process):
Process is for ORA’s internal use, but shared to give others insight and information

9. Updates to HLCRA
Harvard’s Subrecipient Monitoring Policy and Toolkit, and other university-wide and HMS resources can also be found on HLCRA (
The HMS and SPH Subrecipient Monitoring Committees recently collaborated to update subaward-related content on HLCRA:
Subaward resources can now be found under Resources > Award Lifecycle > Proposal Development > Preparing a Proposal > Inclusion of Subawards.
Previous “Subaward FAQs” section has been deleted; this information is covered in other topic-specific pages.
Information relating to subrecipient monitoring can still be found under Resources > Award Lifecycle > Award Management. New tabs have been added which provide links to University-wide subrecipient monitoring policies and resources.

10. Policy and Toolkit
Harvard’s Subrecipient Monitoring Policy and Toolkit are published on the OSP website and are also available on HLCRA. (
Minor changes made recently to reflect transition of risk assessment database information into GMAS
Toolkit has been recently updated to include:
Changes to the Database User’s guide
Advance Payment Guidance
Minor language changes throughout the Toolkit

11. OBI Quarterly Reports
Departments will remain responsible for completing quarterly spreadsheets
No change to process, but enhancements to OBI in process

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