1. “SPEAR” W ORKSHOP O CTOBER 19 & 30, 2015 ANGELLE GOMEZ S UBAWARD R ISK A SSESSMENT / MONITORING

2. Subawards Risk Assessment Monitoring Closeout

3. Subawards Florida State University (FSU), as a prime recipient, is responsible for ensuring that all awarded sponsored activities, including that of its subrecipients, are compliant with award terms and conditions and applicable federal and state regulations. FSU shall monitor subrecipients as necessary to ensure that federal and state awards are used for authorized purposes in compliance with all applicable laws, regulations, and the provisions of award agreements and that performance goals are achieved.

4. Risk Assessment §200.331 (b) b ) Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraph (e) of this section, which may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).

5. Risk Assessment For each subaward, a Risk Assessment is completed and a score is assigned.  The Risk assessment has three specific areas that are looked at:  Threshold  Institution Specific  Project Specific

6. Risk Assessment Threshold Questions  Go/No-Go Decision – STOP if yes  Subrecipient or PI– debarred or suspended?  Potential or identified conflict of interest?  If No, decide whether to discuss alternatives with PI  Established accounting systems.  Acceptable procurement system, in accordance with GAAP.  Audit completed in accordance with 2 CFR 200 or A-133 for most recent fiscal year.

7. Risk Assessment Institution Specific  Foreign or domestic  Type of entity  Years of existence  Basis for requesting F&A costs (i.e. negotiated agreement)  Audit results  Subrecipient’s conflict of interest policy

8. Risk Assessment Project Specific  Prime award details  Amount of subcontract  Percentage of prime award being subcontracted  If IACUC or IRB approval is required  Mandatory cost share being provided  Deliverable details in relation to work performed

9. Risk Assessment This score represents the level of risk that the subaward poses to the University with respect to non-compliance. The risk classifications are as follows:  Low Risk  Medium Risk  High Risk SRA focuses on more frequent and substantive monitoring efforts for subawards with a higher risk score.

10. Monitoring Low Risk  Review audit reports and evaluate any findings.  Review subrecipient invoices – ensure work is performed within the period of performance; the invoice is complete and accurate; the expenditures are allowable per the subaward budget, subaward terms and conditions as well as laws, regulations and University policies; the PI approves the invoice as acceptable to issue payment.

11. Monitoring Medium Risk  Perform all review steps listed in the Low Risk Category.  Additional Steps include:  Determine how material the audit findings are in the audit report and whether they pose an increased risk to the subrecipient’s ability to be in compliance and carry out the scope of work.  Request expenditure detail as supporting documentation for invoices on a monthly or quarterly basis; evaluate documentation received for sufficiency.  Request and review financial reports more frequently, if possible.

12. Monitoring High Risk  Perform all steps in the Low and Medium Risk Categories  Additional steps include:  Request expenditure detail as supporting documentation for all invoices.  Maintain regular contact with PI to ensure subrecipient is meeting programmatic expectations and document communication in subaward file.  Exercise the option to audit or consider performing a site visit or desk review.  Withhold payments to subrecipient if deemed necessary.

13. Monitoring Medium/High Risks  If a subrecipient is determined to be medium to high risk, additional monitoring/invoicing language may be included in the subaward document.  If additional monitoring is necessary, additional language will be included that identifies how the subrecipient may remove the additional monitoring requirements.

14. Monitoring Example of Additional Monitoring Requirements 1) Providing subrecipients with training and technical assistance on program-related matters; and 2) Performing on-site reviews of the subrecipient’s program operations.

15. Monitoring SRA vs. PI Responsibilities  SRA responsibilities  Changes to the subcontract document (with PI concurrence).  Review and approval of subcontract invoices (with PI concurrence).  Documentation of financial monitoring efforts.  PI responsibilities  Provides signature on all invoices certifying work is performed to their satisfaction and in accordance to the terms and conditions of the subcontract.  Review and approval of technical performance reports.  Documentation of programmatic monitoring efforts.

16. Monitoring Ongoing Monitoring - PI  The PI should review technical performance reports or other specified deliverables on a timely basis.  Any unforeseen issues should be documented, investigated, and resolved.  The PI and department administrator(s) should perform an expense to budget comparison for cost-reimbursement sub agreements. The subrecipient’s invoices must show both current period and cumulative expenses-to budget.

17. Monitoring Ongoing Monitoring - PI  The PI and department administrator(s) should review invoices regularly and document their review in the grant file.  Such documentation may include, for example:  PI initials or authorizing signature on invoices,  email communications,  notes of meetings with the department/school grant administrator, etc.

18. Monitoring Subrecipient Audit Verification  SRA obtains the most recent audit and fiscal year end data at the proposal stage through the Subrecipient Commitment Form.  At the award stage, this information is populated in the Risk Assessment spreadsheet. The SRA Accounting Manager is responsible for evaluating when an audit report should be requested based on the fiscal year end date maintained for each subrecipient.

19. Monitoring Annual Audit Verification  The audit verification letter is submitted to current subrecipients to request their most recent audit report. If the subrecipient has previously identified a website link to the audit report, SRA will attempt to locate the report online.

20. Subaward Closeout Occurs at the end of the project period  Joint determination between SRA and PI to ensure subrecipient has fulfilled all responsibilities under the subcontract.  Final Invoice received by SRA.  PI certification obtained  Invoice submitted for payment  Subcontract closeout certification form.  Ensure all reports/deliverables submitted and are acceptable  Final property report received  Final invention report received  PI certification on closeout form

21. Questions? Angelle Gomez: 644-8653; agomez@fsu.eduagomez@fsu.edu Subcontract Analyst : TBD