Risk Assessment and Subrecipient Monitoring

Transcription

1 Risk Assessment and Subrecipient Monitoring Portia Garvey, Assistant Director, Preaward Services Research Office Research 0

2 Risk Assessment and Subrecipient Monitoring Research

3 Learning Objectives Understand Importance the WHAT and WHY behind subaward risk assessments and subaward monitoring Understand Considerations and Appropriate Approaches to Effectively Monitor Subawards Activity Discuss Roles and Responsibilities Critical to Success Overview of Subaward Invoicing Process Leave with Valuable Tips and Recommendations to Avoid Issues and Delays During the Life of the Award and Close-Out Research 2

4 What is Risk Assessments/Subrecipient Monitoring?? The process of providing oversight on subawards throughout the lifecycle, including: Obtaining appropriate information in support of your proposal Reviewing appropriateness of the subawardee Determining risk associated with a subawardee Monitoring activities during the period of performance of the subaward Research 3

5 What about Uniform Guidance?? States that pass-through entities must monitor the activities of subrecipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. The Uniform Guidance replaces the term Federal awards with the term subaward, clarifying that pass-through entities are primarily responsible for evaluating and monitoring subrecipient institutions on awards for which they are directly accountable. That said, passthrough entities do need to verify (as opposed to ensure) that subrecipients are audited in accordance with the Uniform Guidance. Research 4

6 Proposal Preparation Deciding at the proposal time if you are working with a sub, consultant or vendor Not always obvious Do your homework Share chart with PI to help determine Research 5

7 Award Notification Received award notification Subaward has been included in the budget Let the risk assessment begin!!! Research 6

8 When does Subaward Risk Assessment Occur? Receipt of award identification of subaward in budget Department initiates requisition for subaward RO initiates risk assessment documentation Risk assessment includes series of questions specific to subawardee (most information pulled from subrecipient commitment form)**** ***Delays may occur if appropriate paperwork and subrecipient commitment form was not obtained at proposal time College or Department name here 7

9 What Determines Risk Risk Assessment includes series of questions some questions with specific scoring Questions resulting in a score of 3 automatically identifies assessment as high risk category High risk subawards are reviewed by RO management team In high risk instances, RO will contact PI/department administrator Recommendations will be provided to decrease/address risk areas or preventative terms/conditions may be included in the subaward High risk category does not necessarily equate to not working with the subawardee College or Department name here 8

10 High Risk Factors Foreign Sub Delays in Invoicing/Issues with Invoicing A-133 Audit Findings or No A-133 Done No A-133 may require mini audit questionnaire Other (Less than 1 Year in Operation, Significant Amt of $ to Sub) Research 9

11 Risk Assessment Completed Based on assessment of subawardee, RO may include special language to be added to subaward (reviewed/acceptable by PI) Possible language Additional financial reporting Request for receipts at various invoicing intervals Release of partial funding vs. full year funding Include site audits Monthly or quarterly calls with subawardee programmatic review College or Department name here 10

12 Risk Assessment Completed Risk assessments are filed in RO; processed for each new subaward Documentation utilized to support KMPG annual audit College or Department name here 11

13 Subaward Package Assembled RO prepares documentation for submission to sub Based on assessment, if sub is high risk, may add special requirements (reporting, auditing, special reviews, milestones) Obtains approval from PI RO executes subaward documentation Research 12

14 Monitoring Considerations During Cycle of Subaward Are invoices received timely critical to good award management Carryover considerations (large carry over amounts) Performance vs. Spending (program calls with PIs) If during the cycle of the award the above are identified as issues, consider add special terms as a monitoring mechanism (reporting, auditing, special reviews, milestones or other) Discuss with PI Research 13

15 Invoicing Invoices must be submitted by subawardee to subaward inbox for payment No paper copies being accepted No copies accepted unless the subawardee submits the invoice directly to the subaward inbox Research 14

16 Invoicing/Payment Invoice webform is initiated by the RO invoicing coordinator (initial review to ensure mandatory info letterhead, certification, PO) No longer using approval Electronic approvals include department, PI, and RO (others as necessary) Procurement issues payment once RO C/G does final approval of invoice (typically paid each Wednesday) College or Department name here 15

17 Invoicing/Payment What happens when? Delay in invoicing or no invoices until end Department award management/monthly review of award and expenses should identify this Depending on relationship with subawardee, either RO can reach out or department can reach out to subaward Determine the cause or problem/delay Issue with delay in invoicing may overstate funds causing issue through life of award Can cause issue at close-out as well College or Department name here 16

18 Subaward Monitoring Checklist Provides a consistent approach to review of invoices Low volume of subawards Training tool for others in department College or Department name here 17

19 Subaward Monitoring Checklist - Each invoice needs to be checked for accuracy! - Use this checklist for each invoice to check for compliance - f/training/subaward-monitoringchecklist.pdf Research 18

20 Questions to Consider During Review of Invoices Is the subrecipient s work progressing according to schedule? Are deliverables and reports being provided on time or in a timely manner? Are all compliance considerations up-to-date? Are funds being spent according to the budget and within the project timelines? Does cumulative invoice amount align? Research 19

21 Keeping on Track! Keep track of sub spending and invoice payments on UDataGlance UData will keep track of PO s as an obligation Query can be used to view what has been committed and expended for purchase order by PS Account. - GMQ_PO_ACTIVITY_SUM Research 20

22 SUMMARY Why Subrecipient Monitoring is Important Questions to Ask Risk Assessment How it Works Benefits Electronic Subaward Invoice Process Monitoring Checklist Research 21

23 TAKE AWAY We All Play a Role in the Process College or Department name here 22

24 QUESTIONS?? Research 23

25 Research 24