This section provides guidance to the university community regarding subrecipient contracting and monitoring to comply with OMB Circular A-133.
Upon completion of the contracting process, award/contract from UWF to subrecipient is transferred to the Grants & Contracts Financial Manager for functions related to establishing encumbrances, processing invoices, and monitoring required financial reporting.
RSP assists PIs in requesting any required reports such as invention disclosure, technical reports to incorporate in UWF reports to sponsor agency.
RSP assists PIs in compiling final financial-related reports such as financial expenditure reports, inventory/property reports, and supporting documentation.
PIs have primary responsibility for monitoring subrecipients to ensure compliance with federal regulations and both prime and subrecipient award terms and conditions.
Departmental business managers have responsibility for assisting PIs in discharging their monitoring responsibilities, for reviewing invoices from subrecipients and questioning expenditures if necessary, and for maintaining documentation of monitoring efforts.
RSP has responsibility for ensuring that the university's subrecipient monitoring procedures are compliant with federal and other applicable regulations and are consistent with sound business practices. RSP will provide further training, monitoring and guidance in interpreting applicable regulations and subrecipient award terms and conditions, and in interpreting and executing these guidelines. Additionally, RSP will conduct web site reviews of any subrecipient published OMB Circular A-133 audits to ensure they are conducted and request copies whenever electronic version are not available as indicated in the contract document through the Federal Single Audit Clearinghouse web site.
In order to meet requirements for OMB Circular A-133 compliance, the university must meet the requirements regarding subrecipients’ performance and compliance under any prime awards or contracts for which it is the fiscal agent of record. To accomplish this requirement, the operating procedures above have been developed to provide an overview of the requirements, work flow, and responsibilities. RSP assists and collaborates with the PI(s) to perform contracting and financial monitoring. The PI is the primary responsible party for ensuring that sponsored research funds (including subrecipient payments and deliverables) are used as awarded from the sponsor and that costs incurred are “allowable, reasonable, and allocable” and that required reporting is accomplished as outlined in the prime award document.
For assistance, PIs are urged to contact the department’s business manager, chair/director, or RSP staff for specific requests or assistance.