联邦补助金次级奖励风险评估与监测 Policy

负责人: 教务长办公室
相关法律 & 政策: CFR 200.330 to 200.331, 200.338, 200.425, 200.501, 200.521

范围

This policy applies to 威尼斯游戏大厅 subawards supported by federal funds to ensure compliance with the Uniform Guidance (2 CFR 200) for subawards issued to other institutions for which Carroll is the pass-through entity (PTE).

定义

传递实体(PTE): A non-federal entity that provides a subaward to a subrecipient to carry out part of a federal program; also referred to as the prime or lead awardee or institution.

收件人: A non-federal entity that receives a federal award directly from a federal awarding agency to carry out an activity under a federal program; does not include subrecipients.

Subaward: An award provided by a PTE to a subrecipient for the subrecipient to carry out part of a federal award received by the PTE; does not include payments to contractor or payments to an individual that participates in/benefits from a federal program.

Subrecipient: A non-federal entity that receives a subaward from a PTE to carry out part of a federal program; does not include a contractor or an individual that participates in/benefits from such a program.
 

合规

分收件人风险评估政策:
在作为传递实体(PTE)颁发奖项之前, an assessment of the subrecipient’s risk of noncompliance with Federal statutes, 规定, 以及分包合同的条款和条件 must be completed for the purposes of determining the appropriate level of subrecipient monitoring. 考虑的因素包括:
  1. The subrecipient’s prior experience with the same or similar subawards;
  2. The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F – Audit requirements, and the extent to which the same or similar subaward has been audited as a major program;
  3. Whether the subrecipient has new personnel or new or substantially changed systems; and
  4. The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency.)
次受奖人将由资助工作人员评估, with additional review by the Associate Vice President for Finance and Administration and 大学 Risk Manager as necessary.

子收件人监控策略:
Subrecipient monitoring can take on various forms and is not limited to the practices described below. 2 CFR 200 outlines the following forms of monitoring activities necessary to ensure that the subaward is used for authorized purposes, 遵守联邦法规, 规定, 以及分包合同的条款和条件.
对子收件人的监控必须包括:
  1. Reviewing financial reports required by the pass-through entity (业务办公室).
  2. Reviewing performance reports required by the pass-through entity (授予员工).
  3. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, 现场评审, 和其他方式(PI), 授予员工, 及商务处).
  4. Issuing a management decision for audit findings pertaining to the Federal award provided to the Subrecipient from the pass-through entity as required by 2 CFR 200.521(商务办事处).
  5. Verify that every subrecipient is audited as required by Subpart F – Audit requirements of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set form in 2 CFR 200.501(营业部).
  6. 考虑子收件人的审计结果在哪里, 现场评审, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity’s own records (商务及资助处职员).
  7. Consider taking enforcement action against noncompliant subrecipients as described in 2 CFR 200.338(商务及资助处职员).
Depending on the results of the subrecipient’s risk assessment, the following monitoring tools may be used to ensure proper accountability and compliance with program requirements and achievement of performance goals:
  1. Providing subrecipients with training and technical assistance on program-related matters;
  2. Performing 现场评审 of the subrecipient’s program operations;
  3. Arranging for agreed upon procedures engagements as described in 2 CRS 200.425.
过程:
  1. Complete the subaward data collection form to initiate the subcontract (授予员工).
  2. 评估次级收件人的风险(营业处).
  3. Determine the frequency and scope for monitoring programmatic activities of the subrecipient, to include regular contact with the subrecipient and review of annual programmatic reports (商务及资助处职员).
  4. Ensure subrecipients comply with the technical provisions of the subaward (商务及资助处职员).
  5. 监督下级奖励以确保费用是适当的. This includes requesting and tracking subrecipient financial reports (PI 及商务处).
  6. Keep detailed records of any communication regarding subrecipient monitoring, 比如审阅报告, including any unsatisfactory performance by the subrecipient (PI, 商务及资助处职员).
  7. Consider subaward amendments where needed (商务及资助处职员).


 

大学政策

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