1. Subrecipient Monitoring December 7, 2007 Office of Research Services Brown Bag

2. Old Requirement but New Emphasis l A-110 Requirement »Grant recipient must monitor each program, function or activity funded with federal dollars including subawards l A-133 Requirement »Monitor activities of subrecipients as necessary to ensure that federal awards are used for authorized purposes and … that performance goals are achieved

3. University Policy l SPP 2131 » Compliance with Subrecipient Standards of OMB Circular A-133 l SPP 2135 »Monitoring Subrecipients Not Subject to OMB Circular A-133 l Policies define responsibilities

4. Why Now? l Increase in A-133 threshold decreases number of subrecipients covered by single audits l Included in Penn’s A-133 audit l Increased scrutiny of all grant activities l False Claim Act and Qui Tam Cases »10 fold increase since 1986

5. Recent OIG Audits l University of Massachusetts Medical School »Subawards to Yale and Roger Williams Hospital »Refund to NIH totaling $249,525 l Dartmouth College »$716,522 in subaward costs were questioned due to lack of procedures and documentation related subrecipient monitoring

6. Who is Responsible? l Principal Investigator »Reviews scope of work from subawardee »Certifies that budget is appropriate for scope of work »Approves invoices certifying that the work was completed satisfactorily »Determines additional funding based on progress »Requests reports as needed

7. It Takes a Village l Business Administrator »Collects institutional approvals from subawardee »Send Subaward request Form to ORS »Documents PI approvals of invoices prior to authorizing payment »Reviews invoicing prior to requesting additional funds

8. ORS Workflow Process l Contract Admin/Assoc. Director »Insures complete documentation pkge. »Checks request against NOGA »Forward to subcontract administrator for monitoring »Enters information into activity log for tracking purposes

9. ORS Workflow Process l Subcontract Administrator »Checks if subrecipient is subject to A-133 –If yes, obtains most recent report –If no, requests audited financial statement »Forwards any A-133 reports with significant findings and all non-A-133 financial information to Post-Award Director for review »Checks for debarment/suspension »Prepares and assembles subcontract package

10. ORS Workflow Process l Front Office Staff »Sends completed subcontract via email or hard-copy via UPS »Issues BEN memo when subcontract is fully executed

11. We Heard You l NEED: speed subcontract processing time without compromising compliance »Eliminated requests for duplicate documentation »ORS now responsible to secure F&A rate agreements »Sending subcontracts out unsigned pending receipt of regulatory documents »Emailing subcontracts instead of hard-copy UPS whenever possible »Accepting emailed subcontracts from subrecipient »Issuing unilateral modifications where appropriate

12. Next Steps l Communicating with our Peer Institutions about Best Practices l Participating in FDP A-133 pilot l Panel Discussion planned for Winter 2008