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The University (the monitoring organization) is responsible throughout the life of a subaward to monitor the activities of subrecipients to ensure that the subaward is being managed consistently within authorized purposes, in compliance with Federal Statutes and regulations. This includes:

• As applicable, the terms and conditions of the subaward, particularly those outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (, commonly known as "Uniform Guidance").
• That the subrecipient’s technical progress is demonstrated and/or performance goals are achieved throughout the life of the subaward.

In addition to the necessary Annual Audit Certification, Grants Accounting has developed a procedure to begin reviewing subrecipient’s financial performance through select desk-reviews to ensure that the University is properly monitoring subrecipients. This process is a risk-based approach to subrecipient monitoring, with how often and how closely things are monitored, driven by the terms of the prime sponsor award.

Desk Review Defined

A subrecipient desk review is a process that organizations receiving sponsored funds use to evaluate and monitor the activities of their subrecipients. Below is an overview of the key elements associated with the process that Grants Accounting will use.

Purpose and Scope of Desk Reviews

The primary goal of a desk review is to ensure that the subrecipient is compliant with the terms and conditions of the federal award and applicable federal regulations. This includes confirming that:

• Financial records are accurate.
• Expenditures are allowable, allocable, and reasonable.
• The subrecipient is following the appropriate financial and programmatic reporting requirements.
• The subrecipient is using federal funds in accordance with the intended purpose.

Desk Review Process

In general, desk reviews will be conducted remotely, whereas the monitoring organization reviews the documentation submitted by the subrecipient without an on-site visit. Key steps in the desk review process include:

• Collecting Documentation: Obtain all necessary documentation from the subrecipient, such as:
  • Financial reports (e.g., invoices, bank statements).
  • Programmatic reports (e.g., performance progress reports).
  • Documents that demonstrate compliance with federal award requirements.
  • Audit reports (if applicable).
  • Subrecipient agreements.
• Assessing Compliance with Federal Regulations: Review the documents provided for compliance with federal requirements under the Uniform Guidance (2 CFR 200), such as:
  • Proper allocation of costs.
  • Correct use of federal funds.
  • Timely and accurate reporting.
• Assessing Internal Controls: Determine whether the subrecipient has strong internal controls in place to prevent fraud, waste, and abuse of federal funds. This might include a review of the subrecipient’s policies, procedures, and financial management systems.
• Analyzing Performance Data: Evaluate whether the subrecipient is meeting the goals and objectives of the federal award and whether there are any significant discrepancies in performance.
• Risk Assessment: Based on the desk review, Grants Accounting will assess the risk level associated with the subrecipient’s management and use of the federal funds. Higher-risk subrecipients might require more frequent reviews or on-site monitoring.

Documentation and Reporting

After the desk review, the Grants Accounting Office will document findings, if any, which may include:

• Areas of concern or non-compliance.
• Recommendations for corrective actions.
• Any necessary follow-up actions, including additional monitoring or training for the subrecipient.

This documentation will be detailed, clear, and concise, ensuring that the findings are understandable for both the subrecipient and the managing PI.

Corrective Action Plan

If deficiencies or non-compliance are identified, Grants Accounting will work with the Office of Research and Sponsored Programs (ORSP) to determine necessary steps. Generally, a corrective action plan should be developed and communicated to the subrecipient. This plan typically includes:

• Specific actions the subrecipient must take to address the issues.
• Deadlines for corrective actions.
• Additional training or technical assistance if necessary.

Follow-up and Continuous Monitoring

Desk reviews may not be a one-time activity. We will continuously monitor subrecipients, especially if there are concerns about compliance or performance. Follow-up desk reviews may be necessary, and certain high-risk subrecipients may require on-site monitoring visits.

Best Practices for Subrecipient Desk Reviews

Grants Accounting will follow best practice techniques when completing desk reviews of subrecipients. These include:

• Clear Communication: Ensure that all expectations and required documentation are communicated clearly to the subrecipient.
• Consistency: Apply the same review procedures across all subrecipients to ensure fairness and consistency.
• Timely Follow-Up: Address issues promptly to prevent them from becoming larger compliance problems.
• Training and Technical Assistance: Offer support to subrecipients as needed, especially when deficiencies or misunderstandings are identified.

Conclusion

Subrecipient desk reviews are an essential part of managing federal awards and ensuring that federal funds are used appropriately. These reviews help to detect potential issues early and ensure that the subrecipient complies with federal rules and regulations.  Grants Accounting will coordinate with PI’s as part of this process and PI’s will be included in the communications to the subrecipient.

Finally, the desk reviews do not replace the responsibility that PI’s are ultimately responsible for overseeing their subawards. PI’s/departments should ensure when working with subrecipients that they clearly understand the terms and conditions of their subaward and monitor them to ensure that they are complying. If PI’s/departments become aware of a noncompliance issue, they are obligated to report that information to ORSP and Grants Accounting.

Questions?

For additional information regarding this process, please email finance.grants@ohio.edu.