Strategies to Meet Industry Standards for Subrecipient Monitoring
The Office of Management and Budget's Uniform Guidance (UG) requires that recipients of federal research dollars actively monitor and guide subrecipient compliance.
These efforts are one of the 12 Compliance Requirements of the Single Audit, with a focus on internal controls. Organizations are faced with the need to ensure their processes and documentation align with industry best standards associated with subrecipient monitoring, while managing the challenge of limited resources to develop these controls.
As part of the UG, explicit subrecipient monitoring requirements were set forth that were not previously reflected in other regulations. These include:
- Assessing a sub-grantee’s ability to implement and manage award activities
- Incorporating additional monitoring requirements in the subrecipient agreement based on the assessment
- Determining contractor or subrecipient status
Institutions must update their policies and procedures to align to these requirements and create procedures that will be both consistently followed and documented across multiple departments. More than risk assessments and invoice review, subrecipient monitoring should be an active, ongoing process throughout the life of the award.
Huron recently developed a Subrecipient Monitoring Toolkit that rapidly aligns subrecipient monitoring activities with industry best practices, while limiting the impact on staff and other institutional resources. Before implementing the Toolkit, Huron policy experts execute an assessment of an institution’s current subrecipient monitoring controls. This includes a review of all current policies, procedures and tools, as well as interviews with staff and faculty that contribute to subrecipient monitoring activities. Huron then uses the toolkit to address areas of identified risk, resulting in up to 15 documents that create appropriate safeguards in this area, and guide training and systematic adherence.
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