Executive Council

Authorizes Release:

Provost and Vice President for Academic Affairs

Responsible Area:

Office of Sponsored Projects, Academic Research and Compliance (SPARC)

Review Cycle:

Annually or as required

Last Review:

September 2022

Related Policies and Additional References:



St. Mary’s University complies with OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) (“Uniform Guidance”), specifically sections 200.331-200.333 and requires prime recipients of federal funds to monitor subawards and to ensure subrecipients meet the audit requirements in Subpart F and use funds in accordance with applicable laws, regulations, and terms of the award.


Pass-through entity (2 CFR 200.74): Pass-through entity means a non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program.

Subaward (2 CFR 200.92): Subaward means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of the Federal program. A subaward may be provided through any form of legal agreement, including an
agreement that the pass-through entity considers a contract.

Subrecipient (2 CFR 200.93): Subrecipient means a non-Federal entity that receives a subaward from a
pass-through entity to carry out part of a Federal program; but does not include an individual that is a
beneficiary of such program. A subrecipient may also be a recipient of other Federal awards directly
from a Federal awarding agency.

Distinction Between a Subrecipient and a Contractor

Subrecipient – A subaward is for the purpose of carrying out a portion of a Federal award and creates a
Federal assistance relationship with the subrecipient. Performance should be measured in relation to
whether objectives of a Federal program were met. The subrecipient should have responsibility for
programmatic decision making and adherence to applicable Federal program requirements specified in the
Federal award. In summary, the subrecipient is using Federal funds to carry out a program for public
purpose as opposed to providing goods or services for the benefit of the pass-through entity.

Contractors – A contract is for the purpose of obtaining goods and services for the non-Federal entity’s
own use and creates a procurement relationship with the contractor. The contractor is providing goods
and services within normal business operations and provides similar goods and services to many different
purchasers. Contractors normally operate in a competitive environment and are not subject to compliance
requirements of the Federal program as a result of the agreement.


Subrecipient Pre-Award Monitoring Responsibilities

During the proposal stage, a Principal Investigator working with SPARC Office should:

  • Obtain subrecipient contact and institutional information necessary for complying with St. Mary’s policy on Subrecipient monitoring
  • Obtain a proposed statement of work, a detailed budget, and a budget justification in support of the subrecipient’s project activities.
  • Check to make sure the subrecipient is not suspended or debarred.
  • Obtain evidence from the subrecipient of its willingness to participate in the project and abide by all associated terms and conditions

During the proposal stage, the Grants Finance and Accounting office working with SPARC Office is responsible for verifying subrecipients are audited as required by Uniform Guidance, and obtaining a copy of the most recent audit report. If findings were noted, an assessment is made about whether or not these findings make the subrecipient a high-risk award.

Subrecipient Post-award Monitoring Responsibilities

During the post-award period, the Principal Investigator should:

  • Have regular communication with subrecipients with appropriate inquiries concerning program activities.
  • Monitor programmatic progress and ability of the subrecipient to meet objectives of the subaward.
  • Review technical performance reports or any other specified deliverables on a timely basis.
  • Any issues should be documented, investigated and resolved.
  • Review invoices to compare actual expenditures with proposed budgets. Any questionable items should be resolved before the invoice is submitted for payment.
  • Delay processing final invoices for payment until the PI is satisfied with the work and has received all final technical reports.

During the postaward period, the Grants Finance and Accounting Office will:

  • Obtain copies of single audit reports and management letters when applicable.
  • Verify audit findings are not related to the subaward.
  • If audit findings are related to St. Mary’s subaward, ensure that action is taken and a management decision is issued in accordance with the Uniform Guidance. (2 CFR 200.521).

Subrecipient Closeout Monitoring Responsibilities

Subrecipient must comply with closeout requirements as specified in the terms and conditions of the subaward. PI will ensure the subrecipient has completed all financial, performance, and other reports as required by the terms and conditions of the subaward. Grants Finance and Accounting will ensure all subrecipient invoicing and financial reporting requirements were completed to satisfaction of the funding agency. SPARC will ensure subrecipient is compliant with funding agency closeout requirements.

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