Oklahoma State University’s (OSU)Subrecipient Monitoring
OSU is a decentralized university requiring routing of grants, contracts, cooperative agreements, and other agreements through the college for approval from the PI, Department Head, the Dean, and then through the central offices for approval and assurance of the compliance requirements. OSU follows the Uniform Guidance 2 CFR 200.330 for subrecipient and contractor determinations.
Preaward Stage: Each OSU College or department should use every resource to assure a subrecipientis not a high risk auditee. (i.e., verify on SAM for debarred/suspended, contact Grants & Contracts Financial Administration (GCFA) to verify the subrecipient had no findings for any current or prior annual audit reports received by GCFA. The college should request a copy of their latest audit report for any new OSU subrecipient with OSU. The VPR would make the determination in regard to entering into an agreement with potential subrecipients who are high risk or have audit findings. The VPR office would discuss the technical requirements of the proposal to determine whether another suitable potential subrecipient could complete the work. If not, the subrecipient award may have language added to include additional documentation with each invoice along with any additional terms and conditionsas necessary. The college would be notified and responsible for making the changes to the standard subrecipientaward terms and conditions. Monitoring of invoices, possible desk audits and/or site visits depending on the nature of the finding may be required.
Post Award: Annually, GCFA sends a request to each subrecipient to request their current Audit Report and Management letter or Financial Statements along with a questionnaire. A Compliance Verification Form is also submitted for completion at this time. GCFA monitors/tracks the return of the subrecipients’ information and sends follow-up requests as needed. Once a subrecipient returns their information it is logged into a subrecipient database and reviewed for risk and assessment. During this time GCFA verifies the date the subrecipientsubmitted their audit to the Federal Audit Clearinghouse and assure the certification returned to OSU matches the clearing house data. Audit findings or other concerns are evaluated to determine any significant risk and/or what modifications may need to made to the current agreement. A desk audit may be required and/or a site visit if documentation submitted by the subrecipient is not in compliance. A followup to insure due dates for audit finding corrections have been is also completed. If we find problems with the documentation we would try to work with the subrecipient to correct those problems. If a site visit is required one would be completed. Though this would be an audit of the information, this would also be a teaching/advising meeting to correct any problems. If a significant deficiency is present each of our agreements include a clause/language with ‘the right to terminate for cause’. Language is also included to allow for non-payment and/or repayment, if after working with the subrecipient, any deficiency could not be corrected. The GCFA review process is initiated by the Grant Manager and any issues are reviewed by their Supervisor and a plan is developed to determine any necessary actions needed.
The college PI’s and research administrators are responsible for reviewing each invoice for approval of technical requirements and to adhere or agree to the charges on the invoice in relation to the amount of work completed and technical requirements. Compliance requirements are reviewed by the college fiscal officer or research administrator as well as the PI.
GCFA has designed a databaseto specifically track information on each subrecipient as it is processed through the OSU routing process. Examples of the database are included below.