The Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Final Rule, 2 CFR 200, Dec. 26, 2014, ("Uniform Guidance") sets forth standards for obtaining consistency and uniformity in organizations expending Federal awards. In instances where the award recipient subcontracts with another organization to perform duties required or necessitated by the research award, the award recipient is considered to be a pass-through entity. As a pass-through entity, the award recipient has monitoring obligations to ensure that the sub-recipient uses the award for authorized purposes and that the goals of the award are achieved.
The purpose of this policy is to define subawards, identify roles and responsibilities for those requiring subrecipient monitoring, and provide guidance in fulfilling those responsibilities for grants and sponsored projects.
A "subrecipient" is the legal entity to which a subaward is made and which is accountable to Davidson College for the use of the funds provided in carrying out a portion of the programmatic effort under a sponsored project.
A "subaward" is an award of financial support from Davidson College ("prime recipient") to a qualified organization for the performance of a substantive portion of the program funded under the prime award. It does not include procurement of goods and services funded by a prime award, i.e., vendors are not considered subrecipients.
In accordance with Uniform Guidance 200.331, as a pass-through entity, Davidson College will ensure the following as it relates to the subrecipients of federal funds.
A. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information:
B. Evaluate each subrecipient's risk for noncompliance to determine appropriate monitoring procedures.
C. Consider specific subaward conditions as appropriate.
D. Monitor activities as necessary to ensure compliance with federal regulations.
E. Determine monitoring tools as appropriate based on risk assessment.
F. Ensure that each subrecipient is audited by 200.501 Subpart F - Audit Requirements.
G. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to Davidson College's own records.
H. Consider taking enforcement action for noncompliance.
The Director of Grants and Contracts shall oversee this policy and review it at least once every two years. Changes to this policy shall be made in accordance with the College's Policy on Policies.
Adopted: May 3, 2015
Last Revised: September 23, 2015
Last Reviewed: October 10, 2015