Section: SPONSORED PROGRAMS ADMINISTRATION

Policy Number: 11000.002.005

Policy Title: Subrecipient Monitoring

Policy Effective Date: December 1, 2011

Last Revision Date: December 1, 2011

POLICY OBJECTIVE

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 sponsors requirements for subrecipient monitoring.

POLICY STATEMENT

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.

Benjamin F. Quillian
Executive Vice-Chancellor/Chief Financial Officer

Date: October 31, 2011

APPLICABILITY AND AREAS OF RESPONSIBILITY

REVISION HISTORY

RESOURCES AND REFERENCE MATERIALS

Useful Guidelines:

Definitions:

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 subrecipient to a lower tier subrecipient.
Subrecipient: 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 subrecipient 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.

Related Principles:

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:

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
sderosa@calstate.edu

Subject Expert:

Ms. Sandra Nordahl
snordahl@foundation.sdsu.edu

Ms. Jeanne Dittman
jdittman@foundation.sjsu.edu

Ms. Cindy Lopez
cindy_lopez@csumb.edu

Ms. Carol Sager
casager@csuchico.edu

Affinity Group:

RAC, CCRO, FOA, CABO, HR

CSU POLICY