Federal Grant Subrecipient Monitoring Policy

Policy Statement

Adelphi evaluates and monitors the financial and programmatic performance of Subrecipients, and assesses their capacity to properly manage a Subaward. The university’s objective is to monitor that sponsor funds are properly spent, that performance goals are met, and that Subrecipients comply with all applicable law, regulations, and prime award terms. The university may impose specific controls, as needed, for certain Subrecipients based on relevant risk factors. The terms of the Subrecipient’s relationship with the university are documented in a written Subaward agreement between the university and the Subrecipient organization.

Reason for Policy

By virtue of accepting a sponsored project, the university becomes responsible for the financial and programmatic monitoring of the sponsor’s funds. Accordingly, when the university enters into a Subaward and assigns responsibility for conducting a portion of its sponsored project work to a Subrecipient, the university remains responsible to the sponsor for management of funds and for meeting performance goals. Consistent with federal, state, and local regulations, and to ensure proper stewardship of sponsored projects, the university undertakes certain activities to monitor Subrecipients, including but not limited to Subrecipient prequalification, reporting, site visits, regular contact, and other means to provide reasonable assurance that Subrecipients administer and perform Subawards in compliance with applicable law, regulations, and the provisions of the university’s sponsored projects.

This policy applies to all Subawards issued under all sponsored projects awarded to the university regardless of the primary source of funding. This policy does not apply to consultant agreements or the procurement of goods or services from Contractors.

Who Is Governed by this Policy

Faculty and Staff

Policy

Refer to “Federal Grant Sub-recipient Monitoring Policy” (page 26) in the Financial and Administrative Reference Guide.

Definitions

This policy does not have definitions associated with it at this time. Upon periodic policy review this area will be evaluated to determine if additional information is needed to supplement the policy.

Forms

This policy does not have forms associated with it at this time. Upon periodic policy review this area will be evaluated to determine if additional information is needed to supplement the policy.

Related Information

Grant Administration

Document History

• Last Reviewed Date: December 14, 2017
• Last Revised Date: December 14, 2017
• Policy Origination Date: Not known

Who Approved This  Policy

Michael J. McLeod, Director of Financial Operations and Associate Vice President