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:

  1. 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.
  2. Ensure that every sub-award is clearly identified to the sub-recipient as a sub-award and includes the following information:
  1. 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
  1. Flow-down requirements imposed on sub-recipient
  2. Any additional requirements imposed on sub-recipient
  3. Sub-recipient's federally-negotiated indirect cost rate agreement
  4. 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.
  5. Appropriate terms and conditions concerning closeout of the sub-award.
  1. Evaluate each sub-recipient's risk for noncompliance to determine appropriate monitoring procedures.
  2. Consider specific sub-award conditions as appropriate.
  3. 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.
  1. Determine monitoring tools as appropriate based on risk assessment.
  2. Ensure that each sub-recipient is audited by 200.501 Subpart F - Audit Requirements.
  3. 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.
  4. 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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