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Policy 3.6.5.3
Policy and Procedures Manual
Classification Number: 3.6.5.3
Inception: March 9, 51³Ô¹ÏÍøÊÓƵ
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SUBJECT: SUB-AWARD MONITORING FOR FEDERAL GRANTS
In accordance with Uniform Guidance 200.331, as a pass-through entity, 51³Ô¹ÏÍøÊÓƵ Baptist University (WBU) will ensure the following as it relates to the sub-recipients of federal funds:
- Ensure the sub-recipient has not been Suspended or Debarred by the federal government by checking the System for Award Management web site ( ). The Office of Grants and Contracts will document the Suspension and Debarment verification by including a screen print of the Exclusions search in the sub-award file.
- Ensure that every sub-award is clearly identified to the sub-recipient as a sub-award and includes the following information:
- Federal Award Identification
- Sub-recipient DUNS number or Unique Entity Identifier (UEI)
- Sub-recipient Name (must match the DUNS number or UEI)
- Federal Award Identification Number (FAIN)
- Federal Award Date
- Sub-award Period of Performance Start and End Date
- Amount of Federal Funds obligated by this action
- Total Amount of Federal Funds Obligated to the sub-recipient
- Total Amount of the Federal Award
- Federal Award Project Description
- Name of Federal Awarding Agency
- Name of Pass-Through Entity (Davidson College)
- Contact information for awarding official
- CFDA Number and Name
- Identification of whether the award is R&D
- Indirect Cost Rate for the Federal Award
- Flow-down requirements imposed on sub-recipient
- Any additional requirements imposed on sub-recipient
- Sub-recipient's federally-negotiated indirect cost rate agreement
- A requirement that the sub-recipient permit external auditors for 51³Ô¹ÏÍøÊÓƵ Baptist University access to the sub-recipient's records and financial statements as necessary for audit requirements.
- Appropriate terms and conditions concerning closeout of the sub-award.
- Evaluate each sub-recipient's risk for noncompliance to determine appropriate monitoring procedures.
- Consider specific sub-award conditions as appropriate.
- Monitor activities as necessary to ensure compliance with federal regulations.
- Review financial and programmatic reports.
- Follow up on audit findings to ensure timely and appropriate action.
- Issue a management decision for audit findings.
- Determine monitoring tools as appropriate based on risk assessment.
- Ensure that each sub-recipient is audited by 200.501 Subpart F - Audit Requirements.
- Consider whether the results of the sub-recipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to 51³Ô¹ÏÍøÊÓƵ Baptist University's own records.
- Consider taking enforcement action for noncompliance.
Contact for Interpretation: Chief Financial Officer
This policy statement supersedes all previous policy statements on this subject.
Revisions:
03/09/51³Ô¹ÏÍøÊÓƵ – Inception
Printable Policy 3.6.5.3 Sub-award Monitoring for Federal Grants
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