Section: SPONSORED PROGRAMS ADMINISTRATION
|Section 11000 Policies|
Policy Number: 11000.002.005
Policy Title: Subrecipient Monitoring
Policy Effective Date: December 1, 2011
Last Revision Date: December 1, 2011
(see revision history)
It is the policy of the California State University (CSU) that each campus shall have financial controls and procedures in place that ensure compliance with sponsor requirements for subrecipient monitoring.
This policy provides guidance to the CSU to ensure financial and programmatic responsibility for contractual subrecipient relationships in accordance with sponsor requirements.
The campus President or designee must ensure that procedures established for subrecipient risk assessment and monitoring are in compliance with the federal OMB Circular A-133, applicable standards of other sponsors, CSU regulations, and campus policies. Campus procedures should provide consideration for documentation of compliance with minimum requirements of OMB Circular A-133 as it relates to subrecipient monitoring, giving consideration to high risk subrecipients as necessary.
This policy does not apply to consultant agreements or procurement of goods or services from vendors.
Executive Vice-Chancellor/Chief Financial Officer
Date: October 31, 2011
APPLICABILITY AND AREAS OF RESPONSIBILITY
- February 28, 2014 (Annual Review conducted with no change to policy.)
RESOURCES AND REFERENCE MATERIALS
- Sub-award: An award (sub-grant or sub-contract) of financial support from a prime awardee to a qualified organization for the performance of a substantive portion of the programmatic effort funded under the prime award. This term also includes awards made by a sub-recipient to a lower tier sub-recipient.
- Sub-recipient: The legal entity to which a sub-award is made and which is accountable for the use of the funds provided in carrying out a portion of the prime awardee’s programmatic effort under a sponsored project. A sub-recipient has responsibility for programmatic and/or administrative decision making and adherence to the applicable sponsor program compliance requirements. The term may include institutions of higher education, non-profit organizations, for-profit corporations, and foreign or international organizations at the discretion of the Federal awarding agency.
- Vendor: A vendor is responsible for providing goods or services necessary to conduct the research or other programmatic effort and is not responsible for the results of the effort. Vendors provide similar goods or services to many different purchasers. A vendor is only required to meet the terms of the procurement instrument and is not subject to compliance requirements of the Federal program.
- COGR Management Practices Document – http://www.cogr.edu
- Refer to Laws, State Codes, Regulations and Mandates and other guidelines as provided by sponsors.
Sound Business Practices:
- CSUC - http://www.csuchico.edu/resp/formspoltravel/policies/index.shtml
- CSUMB- http://grants.csumb.edu/policies
- CSUN -http://www.csun.edu/sponsoredprograms/subrecipientmonitoring.htm
- CSUSF -http://www.sfsu.edu/~orspwww/_policies/_docs/SubRecipientMonitoringPolicy.pdf
Laws, State Codes, Regulations and Mandates:
- 2 CFR Part 215, Section C (formerly OMB Circular A-110) http://www.whitehouse.gov/omb/circulars_a110/
- OMB Circular A-133: Audits of States, Local Governments, and Non-Profit Organizations and Compliance Supplements http://www.whitehouse.gov/sites/default/files/omb/assets/a133/a133_revised_2007.pdf
- 31 USC 7502(f)(2)(B) Single Audit Act Amendments of 1996 (Pub. L. 104-156) http://www.whitehouse.gov/omb/financial/fin_single_audit.html
COGNIZANT OFFICE(S)CO Manager:
Ms. Sue DeRosa
Director, Sponsored Programs
CSU Office of the Chancellor
Ms. Sandra Nordahl
Ms. Jeanne Dittman
Ms. Cindy Lopez
Ms. Carol Sager
RAC, CCRO, FOA, CABO, HR