St. Mary\u2019s University complies with OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) (\u201cUniform Guidance\u201d), 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.<\/p>\n\n\n\n
Pass-through entity (2 CFR 200.74):<\/strong> Pass-through entity means a non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program. <\/p>\n\n\n\n Subaward (2 CFR 200.92):<\/strong> 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 Subrecipient (2 CFR 200.93):<\/strong> Subrecipient means a non-Federal entity that receives a subaward from a Subrecipient <\/strong>\u2013 A subaward is for the purpose of carrying out a portion of a Federal award and creates a Contractors<\/strong> \u2013 A contract is for the purpose of obtaining goods and services for the non-Federal entity\u2019s Subrecipient Pre-Award Monitoring Responsibilities<\/strong><\/p>\n\n\n\n During the proposal stage, a Principal Investigator working with SPARC Office should:<\/p>\n\n\n\n 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.<\/p>\n\n\n\n Subrecipient Post-award Monitoring Responsibilities<\/strong><\/p>\n\n\n\n During the post-award period, the Principal Investigator should:<\/p>\n\n\n\n During the postaward period, the Grants Finance and Accounting Office will:<\/p>\n\n\n\n Subrecipient Closeout Monitoring Responsibilities<\/strong><\/p>\n\n\n\n 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.<\/p>\n","protected":false},"featured_media":0,"parent":0,"menu_order":0,"template":"","class_list":["post-2915","academic-research","type-academic-research","status-publish","hentry"],"acf":[],"yoast_head":"\n
agreement that the pass-through entity considers a contract.<\/p>\n\n\n\n
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.<\/p>\n\n\n\nDistinction Between a Subrecipient and a Contractor<\/h2>\n\n\n\n
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.<\/p>\n\n\n\n
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.<\/p>\n\n\n\nPolicy<\/h2>\n\n\n\n