Subrecipient Monitoring Policy
University Policy Number 4009
Related Law & Policy:
As a recipient of federal sponsored awards, George Mason University (“Mason”) must comply with the guidelines outlined in the OMB Uniform Guidance. This policy applies to all subawards issued under sponsored projects awarded to Mason without regard to the primary source of funding.
This policy does not apply to consultant agreements or procurement of services from vendors. Policies and procedures regarding those agreements are covered under Mason University Policy 2106.
II. Policy Statement
It is Mason’s policy to adhere to regulations set forth in the Uniform Guidance, section CFR 200.330-1. As such, Mason is responsible for financial and programmatic monitoring of sponsored project funds awarded to Mason that are subawarded to another institution or organization (Subrecipient). To provide the oversight required by federal regulations, it is the policy of Mason to perform a risk assessment prior to issuing a Subaward and implement risk-based monitoring activities accordingly which provide reasonable assurance the Subrecipient will administer the subaward in compliance with regulations and terms of the prime and Subawards.
It is Mason’s policy to ensure that all agreed-upon monitoring activities occur. Mason will consider whether the results of the Subrecipient’s audit, on-site reviews, or other monitoring indicate conditions that require adjustments to the monitoring procedures and Subrecipient’s risk classification.
It is Mason’s policy to execute the following tasks as part of its Subrecipient Monitoring procedures:
- Advise and provide to Subrecipients copies of federal laws or regulations, terms and conditions of the prime award or agreement, and Mason requirements that apply to the subaward or subcontract.
- Provide Subrecipients with information regarding the prime award including Catalog of Federal Domestic Assistance number (CFDA), title, award name and number, award dates, and funding agency, as required by the OMB Uniform Guidance.
- Conduct regular risk assessments of all Subawards and establish appropriate Subrecipient monitoring activities based on the results.
- Monitor costs and activities of Subawards to ensure expenditures are consistent with the budget and scope of work of the subaward. Ensure that the performance goals set forth in the scope of work are being met in a timely manner.
- Verify that Subrecipients expending $750,000 or more in federal awards during the Subrecipient’s fiscal year have met the OMB Uniform Guidance audit requirements for that fiscal year.
- Issue management decisions on audit findings pertaining to any Mason subawards within six months after acceptance of the audit report by the Federal Audit Clearinghouse and ensures that the Subrecipient takes appropriate and timely corrective action.
- Consider whether Subrecipient audit findings or monitoring activities necessitate adjustment of Mason’s records, such as budget modifications or reallocation of resources, a demand for repayment from the Subrecipient, or other remedial measures.
- Require each Subrecipient to permit the sponsor and/or Mason and its auditors to have access to the Subrecipient’s pertinent records and financial statements, as necessary.
- Require each Subrecipient to provide information as required under the Federal Funding Accountability and Transparency Act (FFATA) to meet Mason’s reporting obligations.
Award: An award is financial assistance in the form of a grant or contract with a defined scope of work that provides support or stimulation to accomplish a public purpose.
Pass-Through Entity: A pass-through entity is a non-federal entity that provides an award of federal funds to a Subrecipient to carry out the programmatic activities of a sponsored project. George Mason University is the pass-through entity referenced throughout this policy.
Pass-Through Funds: Funds issued to George Mason University that are then transferred to a Subrecipient per the terms of the subaward.
Subaward:. A subaward is an award issued using pass-through funds to a Subrecipient to perform sponsored award activities per the terms of both the prime and sub awards. Generally, preparation of a subaward includes a Mason determination of the Subrecipient’s share of the federal funding, that the Subrecipient will have its performance measured in relation to whether objectives of a Federal program are met and whether the Subrecipient has responsibility for programmatic decision making. Also known as a subcontract or subgrant. See CFR §200.92 Subaward.
Subrecipient: The non-federal entity receiving pass-through funds from George Mason University to perform sponsored award activities as stated in the Subaward. A Subrecipient shall not be an individual person.
Subrecipient Monitoring: Subrecipient monitoring is the oversight activity performed by George Mason University that provides reasonable assurance that subawards made are being administered in compliance with applicable laws, regulations, and the provisions of the grant or contract agreement. This may include the addition of special terms and conditions within the subaward, additional technical oversight activity, or additional documentation request from the Subrecipient. Subrecipient monitoring activities are based on the risk assessment as referenced in the George Mason Subrecipient Management and Monitoring Procedure.
Vendor Agreement: A Vendor Agreement is a purchasing agreement to procure property or services needed to carry out the project or program under a Federal award. Generally, the vendor provides the services commercially, operates in a competitive environment, provides similar goods/services to multiple different purchasers and retains no rights to intellectual property developed during the execution of the project activities.
Single Audit: A compliance and financial audit required of any institution receiving over $750,000 in federal funds to assure effective management and use of funds as required by the Uniform Guidance. Previously known as the A-133 audit.
Each party named below is responsible for upholding their specified role as part of the Mason Subrecipient Monitoring Policy.
Principal Investigator (PI)
The PI is responsible for identifying the necessary subaward agreements and Subrecipient entities to perform the sponsored project activities and providing the necessary input to inform subaward vs. contract determination, Subrecipient risk assessments, and establishing Subrecipient monitoring activities.
The PI is responsible for monitoring Subrecipients to ensure the subaward is used for the intended purpose and the performance goals are achieved. The PI is responsible for performing and documenting these activities in a timely manner throughout the duration of the subaward and consistent with the statement of work. The PI is responsible for reviewing formal and informal technical reports and maintaining and documenting regular communication with the Subrecipient. As stated in the terms of the subaward or if necessary by circumstance, the PI is responsible for performing site visits to ensure appropriate progress and compliance with Subagreement terms and conditions.
The PI is responsible for reviewing and approving via Banner all invoices submitted by the Subrecipient. The PI verifies that invoice amounts and expense categories are consistent with technical progress and that costs are allowable according to federal, state, university, and sponsor requirements. The PI is responsible for communicating discrepancies or concerns in a timely manner to OSP and prior to approving payment of subaward invoices.
Departmental Administrators are responsible for assisting PIs in their Subrecipient monitoring responsibilities.
Fiscal Services (Controller) is responsible for advising on development of risk mitigation plans for high risk Subrecipients.
Office of Sponsored Programs (OSP)
OSP is responsible for reviewing proposal submissions to assure subaward arrangements are appropriately budgeted in the prime award budget and the appropriate representations, certifications and assurances are in place.
OSP, in consultation with the PI, is responsible for subaward vs. contract determination; performing Subrecipient risk assessments; establishing Subrecipient monitoring activities to ensures compliance with federal, sponsor and university guidelines and regulations; and updating subaward Terms and Conditions appropriately.
OSP is responsible for a pre-review and approval (via Banner) of all subcontract invoices to verify sufficient funding is available, expenses incurred are during the project period of performance, and the correct encumbrance number is utilized. After pre-review, OSP is responsible for routing the invoice to the PI for approval.
OSP is responsible for conducting a risk assessment at the appropriate interval during the lifecycle of each subaward, including a review of the Subrecipient Single Audit and financial questionnaire for non-Single Audit Subrecipients; and ensuring Subrecipients are not debarred or suspended and are eligible to receive federal funds. OSP is responsible for leading issue resolution related to questionable costs, audit issues or high-risk monitoring results.
OSP is responsible for obtaining from the Subrecipient all information required for FFATA compliance and for filing all necessary FFATA reports.
OSP is available to assist PIs and Departmental personnel in the interpretation of Subrecipient monitoring policies and procedures.
Purchasing and Accounts Payable (AP)
The Mason AP department is responsible for initiating the Subrecipient invoice routing / approval process and maintaining record of source documents. After OSP and PI approval, AP is responsible for posting the payment against the proper encumbrance and issuing payment to the Subrecipient.
Office of Risk Management
The Office of Risk Management is responsible for assisting in determining whether a Subrecipient maintains adequate commercial and general liability insurance to conduct the programmatic activities required under the statement of work.
As a recipient of federal funding and as the pass-through entity, Mason assumes the responsibility of ensuring good stewardship of sponsored funding and of providing proper oversight of Subrecipients’ ability to meet monitoring and reporting requirements.
Reference: 2 CFR Section 200.330 Subrecipient and contractor determinations & 2 CFR Section 200.331 Requirements for pass-through entities.
Risk Assessment and Monitoring Guide
Subagreement Original Award File Checklist
Subaward Procedures Checklist
Subaward Modification Checklist
- Request to Initiate New Subagreement Activity Form
- Request to Initiate Modification to Subagreement Activity Form
A. Effective Date:
This policy will become effective upon the date of approval by the Senior Vice President and Provost.
B. Date of Most Recent Review:
VIII. Timetable for Review
This policy and related procedures shall be reviewed and revised, if necessary, annually.
Maurice W. Scherrens
Senior Vice President
Peter N. Stearns
Date approved: May 14, 2008
Revised: February 14,2013
Revised: January 2015
Revised: February 10, 2021