Subrecipient Policy

Effective Date:

December 26, 2014


Monitoring Subrecipients

Policy Review Date:

3 years

Issuing Authority:

Research Foundation President

Responsible Party:

Robert Mason, Senior Director Grants & Contracts Administration

Contact Information:

Justine Gordon, Director Grants & Contracts Administration


Reason for Policy

The Research Foundation is responsible for monitoring the programmatic and financial activities of its subrecipients in order to ensure proper stewardship of sponsored funds. This policy addresses those responsibilities to ensure that both The Research Foundation as prime awardee and subrecipients are in compliance with applicable laws, regulations and with the provisions of the prime award.

Statement of Policy

The Research Foundation must comply with any prime award’s specific requirements for issuance of subawards. All of the terms and conditions applicable to the subaward must be flowed down to the subrecipient. This Subrecipient Policy applies to all subawards issued under sponsored programs made by The Research Foundation, without regard to the primary source of funding.

Additional Federal Requirements

2 CFR Part 200 places certain additional requirements for monitoring and managing subrecipient activities on federally-funded awards. In order to ensure that the Research Foundation is in compliance with federal regulations, the requirements at 2 CFR 200.330-332 shall apply to subrecipient arrangements funded with federal funds. A toolkit has been developed to assist in determination, risk assessment and periodic monitoring of subrecipients.

Refer to [Toolkit - Subrecipient Monitoring and Management]


The following table outlines the responsibilities for compliance with this Policy:

Responsible Party


RF Central

Maintain and enforce this policy and attendant procedures including amendments to reflect future changes

RF Central

Establish guidelines for conducting risk analysis that comply with OMB Uniform Guidance


Conduct determination of subrecipient work and risk analysis for each subaward

RF Central

Maintain subaward agreement templates for use by campuses

Campus (decentralized)

Central Office (Centralized Campuses)

Complete, negotiate, and execute subaward agreements


Periodic monitoring of recipient performance


Make payments to subrecipients in accordance with terms of the subaward agreement after determining satisfactory performance


Subrecipient - An entity that expends funds received from a pass-through entity to carry out objectives of a program.

Prime awardee - The entity granted the award by the sponsor. (The award recipient)

Prime award - The award made directly from the sponsor to the recipient.

Subaward – An award provided by a pass-through entity to an eligible third party (subrecipient), or by a subrecipient to a lower tier recipient, to conduct an essential portion (including the design, performance, and reporting) of the project work in compliance with the sponsor's terms and conditions.

Subaward Agreement – A form of contract that sets forth the terms and conditions that will govern the performance of the Subaward.

Related Information

[Toolkit - Subrecipient Monitoring and Management]

Note: On or after December 26, 2014, 2 CFR Part 200 is effective and applies to all new awards issued. Funding awarded prior to this date and/or incremental funding may still be governed by OMB Circular A-110, A-21 or A-133, depending on the awarding agency’s specific terms and conditions. Specifically, for subawards issued on prime awards subject to A-133, the RF is responsible for determining whether its subrecipients have met the audit requirement outlined in A-133.



Change History


Summary of Change

December 26, 2014

New additional policy with reference to 2 CFR Part 200



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