Subrecipient Monitoring

During-the-Award Monitoring
Principal Investigators (PIs) negotiate subcontracts with subrecipients through the Office of the Vice Provost.  When an agreement is fully executed, it must be submitted to the Office of Sponsored Programs Accounting (SPA) along with a completed Consultant Payment Form.  Once approved by SPA, the Consultant Payment Form is forwarded to Accounts Payable for entry into the commitment system. In addition, the corresponding budget is entered onto the appropriate grant using the range of accounts (5151-5164) set aside for subcontracts.  When invoices are submitted for payment, they are pre-checked by SPA and then sent to the PI for review and signature.  By signing the invoice, the PI is indicating that the costs are reasonable and reflect the work performed.  If the PI chooses to have a designate sign the invoice, the individual must have first-hand knowledge to judge the quantity and quality of the work represented on the invoices.  Once the PI or his/her designate signs, SPA approves the invoice and forwards it to Accounts Payable for payment under the assigned account number.  Issues regarding subrecipient performance should be reported to the Office of the Vice Provost and SPA as soon as possible.

A-133 Compliance
SPA is responsible for ensuring that all subrecipients are in compliance with OMB Circular A-133 requirements.  Assuming Tufts A133 report has been audited by January, SPA sends correspondence to the subrecipients to ensure that they are compliant with A-133 requirements.  Since payments to subcontractors are segregated into a specific range of accounts, a PeopleSoft query is run to identify payments made.  From this list, a letter requesting information on the A-133 audit status of all subrecipients is then sent out to ascertain whether an A-133 report on the subrecipient is necessary, if the A-133 audit has been completed and whether or not there were any findings.  Any subrecipients that indicate there were findings on their A-133 report are required to submit a copy of that report.  In April, a “Second Notice” letter is sent to all subrecipients who have not responded requesting the same information.  In July, follow-up phone calls and e-mails are sent to the remaining subrecipients who have not responded or responded that their audit would be completed at a later date.  A log is maintained to track the status of all subrecipients in regards to the status of their response. If the information has not been received after the July attempt, they will be reviewed with management for final resolution.

Assessment of Subrecipient Risk
Generally, the subrecipients used in research projects at Tufts University are well recognized organizations that participate in research themselves, and most are required to complete their own A-133 audit.  Therefore they must ensure that they have adequate controls and systems as established by their respective institution to monitor grant expenditures.  For those subrecipients not required to complete an A-133 audit, SPA will do a risk assessment based on prior history and may request additional information such as financial reports or may run a Dun & Bradstreet report to complete this assessment.  In addition, PIs are responsible for evaluating the quality of the work performed by subrecipients and ensuring that contractual agreements are met.  Finally in order to ensure A-133 compliance, SPA may request other information (annual reports and source documents) and/or may conduct site visits.

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