Subaward Risk Assessment & Monitoring

The requirements apply to all subawards supported by federal funds that are subject to the Uniform Guidance (UG) (2 CFR 200). This includes subawards issued to other institutions for which UWL is the lead institution and subawards for which UWL is the subrecipient.  In general, subawards subject to this policy are those for which a notice of award was received by the lead institution on or after December 26, 2014.  

Subawards issued to other institutions (i.e., UWL is the lead institution): Prior to submission, such subawards need to have written confirmation of the subrecipient entity’s involvement on file with ORSP.  This confirmation should include, at minimum, confirmation of the entity’s intent to establish appropriate inter-institutional agreements if an award is issued, scope of work, and subaward budget and justification.  The confirmation must be sent to ORSP by an authorized administrative official from the subrecipient (e.g., university ORSP representative).

Subawards issued to UWL: Prior to submission, such subawards must follow the institutional review and approval process for extramural grant applications. Following completion of the approval process, ORSP will issue written confirmation to the lead institution of UWL’s intent to collaborate. This confirmation will include, at minimum, confirmation of UWL’s  intent to establish appropriate inter-institutional agreements if an award is issued, scope of work, and subaward budget and justification. Input from the UWL PI(s) is needed to complete the documentation.

Federal agency requirements: In addition to the materials noted above, federal agencies typically require additional subrecipient documents to be submitted with an application (e.g., CV, current & pending support form). PIs should consult federal program guidelines for a comprehensive list of subrecipient documents required by the agency.

Subawards issued to other institutions (i.e., UWL is the lead institution):

1. The UWL PI should forward to ORSP all award notification documents received from the federal agency.
2. Once a federal award notification is received, ORSP issues a Subaward Data Collection Form to the subrecipient administrative contact for completion.
3. The completed Subaward Data Collection Form, along with input from other campus stakeholders, is used by ORSP to complete the Subrecipient Risk Assessment Matrix.  The Risk Assessment Matrix defines additional actions that may be required for ongoing monitoring and management of the subaward, such as the development of a Risk Management Plan (if appropriate).
4. Following completion of the Risk Assessment Matrix, and development of a Risk Management Plan if needed, a Subaward Agreement is issued by ORSP to the subrecipient for completion and approval.  The Subaward Agreement establishes the terms of the subaward.

 Subawards issued to UWL:

1. The UWL PI should forward to ORSP all award notification documents received from the lead institution. This will likely include subrecipient risk assessment and monitoring information requests and agreements similar to those used by UWL when it is the lead institution.
2. ORSP facilitates completion of the subaward documents required by the lead institution and sends completed documentation to the lead institution’s designated administrative contact.
3. ORSP provides the documentation needed by the Grant Accountant to set up an account.
4. Once account set-up is complete, the Grant Accountant contacts the UWL PI(s) with information on how to access it.

Subawards issued to other institutions (i.e., UWL is the lead institution):

UWL PI(s) share responsibility for and play an integral role in assessing, monitoring, and mitigating risk when working with subrecipients. These responsibilities include but are not limited to the following:

• Following award notification from a federal agency, and before a subaward is issued, the PI’s input is needed by ORSP to complete the Subrecipient Risk Assessment Matrix for each subaward. The PI is one of the signatories of the completed matrix to verify its accuracy.
• If a Subrecipient Risk Management Plan is needed, the PI works with other UWL administrative contacts (e.g., ORSP, Grant Accountant, Contract Administrator/Risk Manager, Department Chair/Unit Director, Dean/Division Head) to develop the plan. The PI is also responsible for carrying out any actions designated in the Risk Management Plan to monitor subrecipient activity and mitigate risk.
• The PI should inform the Grant Accountant of any special needs, concerns, or requirements arising with their subrecipients either before a subaward is issued or as a subaward progresses.
• The PI is responsible for collecting, reviewing, documenting their review, and retaining required programmatic reports from subrecipients.
• The PI also plays a major role in subrecipient monitoring by verifying progress and ensuring invoices submitted by subrecipients are appropriate. A PI’s signature on subrecipient invoices certifies that the subrecipient’s progress is satisfactory; if applicable, any subrecipient programmatic reports due during the period of time covered by the invoice have been received and are satisfactory; and the subrecipient is compliant with the terms of the subaward agreement. PIs are responsible for informing the Grant Accountant if they have received an invoice they cannot sign because of a missing or inadequate report (if applicable) and/or due to dissatisfactory subrecipient progress.
• To ensure timely payment of subrecipient invoices, the PI is required to review and approve subrecipient invoices within 10 days of their receipt and return the approved invoice to the Grant Accountant for payment.  If a PI believes payment should be withheld from a subrecipient for noncompliance with a subaward agreement, they should contact the Grant Accountant immediately.
• To ensure timely submission of final reports, subaward invoices and final reports must be submitted to the Business Office within 45 days of the project end date to allow the university to meet federal agency deadlines.  The PI must be diligent in monitoring the receipt and approval of subrecipient progress reports and final invoices for receipt within this 45-day deadline.

 Subawards issued to UWL:

The responsibilities of UWL PI(s) serving as subrecipients include, but are not limited to, fulfilling the established scope of work, fulfilling project objectives, supplying timely programmatic reports as required by the lead institution and sponsor, working with the Grant Accountant to administer subaward funds, and meeting all other terms of the subaward agreement and sponsor requirements. The PI will also serve as the main point of contact between the lead institution and UWL, and is responsible for disseminating all award-related documentation/information received from the lead institution to appropriate UWL administrative contacts.