If an audit is required, assuring that the subrecipient submits the report, report package or the documents required by. March 1, 2016 read more about subrecipient monitoring under the omb s new super circular shawn miller. A new subrecipient, an inexperienced subrecipient, history of noncompliance, audit findings, sophistication of subrecipients systems and administrative operations. Subrecipient monitoring under omb circular a3 page 8 subrecipient or vendor. Governmental auditing standards and omb circular a3 update. Subrecipient monitoring guidelines purdue university. The characteristics that define a subrecipient versus an entity that is just hired to perform. Ensures that federal awards are used in compliance with laws, regulations, and the provisions of agreements. Determining by inquiry and discussions whether subrecipient met thresholds requiring an audit under omb circular a3. As defined by omb circular a 3, a subrecipient relationship exists when funding from a passthrough entity is provided to perform a portion of the scope of work or objectives of the passthrough entitys award agreement with the awarding agency. This document identifies the procedure and responsibilities for the research foundation rf as a passthrough entity in accordance with omb circular a3. Subrecipient monitoring can take on various forms and is not limited by the practices described below.
Overview of a3 and ug audit requirements preparing for an audit examine roles and responsibilities for subrecipient monitoring identify good business practices for subaward management 2 a3 and ug emphasis. Federal awards expended by subrecipients are subject to audit under circular a 3. Is your organization familiar with federal financial reports so that yes no. Subrecipient monitoring should not be viewed as a series of distinct events, but. Subrecipient monitoring under the omb s new super circular shawn miller originally posted. March 1, 2016 read more about subrecipient monitoring under the ombs new super circular shawn miller. The subrecipient does not have an annual a3 audit 3. A subrecipient relationship exists when funding from a. As defined by omb circular a3, which is the outgoing standard, a subrecipient relationship exists when funding from a passthrough entity is provided to perform a portion of the scope of work or objectives of the passthrough entitys award agreement with the awarding agency. The suggested audit procedures above for internal control and compliance testing may be. Omb circular a3 and omb uniform guidance ug part 200, subpart f, 200. Auditors should specifically ask auditees about, and be alert to, recipient and subrecipient expenditure of funds provided by arra. University of arizona departments compliance with university of. Transfers of federal awards to another component of the same auditee under omb circular a3 do not constitute a subrecipient or vendor relationship.
Subrecipient monitoring the responsibilities of passthrough entities under omb circular a3 bruce morgan, assistant vice chancellor for research administration, university of californiairvine. Subrecipient monitoring under the new uniform guidance. The compliance supplement is available on the internet at. This circular rescinds circular a128, audits of state and local governments, issued april 12, 1985, and supersedes. Ffata put into place a new federal reporting system for direct recipients 2011 omb circular a3 compliance supplement issued of nonarra funds that requires the reporting of certain. Subrecipient monitoring under omb circular a 3 page 8 subrecipient or vendor. Subrecipient monitoring form university of north texas health science center u. Is subrecipient located outside of the united states. Vendor vs subrecipient per omb circular a3 subrecipient means a nonfederal entity that expends federal awards received from a passthrough entity to carry out a federal program, but does not include an individual that is a beneficiary of such a program. The costs of the a3 audit can be considered either directs costs or allocated as part of the grantees indirect costs pool.
The distinction between subawards passthrough grants and procurements under grants contracts has been an issue in single audits conducted under circular a3 as far back as 1997, when the circular was revised, according to lloyd, because funds received as a recipient or subrecipient are subject to audit. Review annually subrecipient risk 1 omb circular a3, appendix b compliance supplement m. Subcontracts and subrecipient monitoring california institute. A subrecipient may also be a recipient of other federal awards directly from a federal. Subrecipient monitoring note kansas state university. The costs of the audit must be approved in the grant budget in order to be. Subcontracts and subrecipient monitoring california institute of technology pasadena, california. Vendor vs subrecipient per omb circular a 3 subrecipient means a nonfederal entity that expends federal awards received from a passthrough entity to carry out a federal program, but does not include an individual that is a beneficiary of such a program. Subcontracts and subrecipient monitoring california. In response to the revision of omb circular a3 and the results of the annual single audit of federal. A qualified audit report, or failure to have a current audit report 6. Subrecipient monitoring the responsibilities of pass.
Or,exempt since we expended subrecipient monitoring under omb circular a 3. For subrecipients that do not comply with omb circular a3, an audit questionnaire must be. Findings on their most recent a 3 audit report that relate to sponsored program activity 2. All dwd grantees are required to submit a list of their subrecipients to dwds oversight division within thirty 30 days of the end of their fiscal year. On or after december 26, 2014, 2 cfr part 200 is effective and applies to all new awards issued. May not be received for four to six months after the end of the fiscal year due to time differences with. Have subrecipients previous subawards with the university of arizona been in good standing.
Subrecipients omb a3 audit or audited financial statements. Your institution pass through entity the subrecipient instructions for auditors on how to audit are in a. Compliance requirements a passthrough entity is responsible for. Monitoring of subrecipients is a collective effort made by the principal investigators, office of scholars hip and sponsored projectsgraduate school ossp, and grant accountant and the subrecipient institution that occurs throughout the life of the subaward.
Circular a3 is issued under the authority of sections 503, 1111, and 7501 et seq. Assure compliance with the requirements of the office of management and budget omb circular a3, audits of states, local governments, and nonprofit. Distinguishing between a subaward and vendor relationship. Because all audits using the 2016 supplement will be performed under 2 cfr part 200, subpart f, i. Your institution pass through entity the subrecipient instructions for auditors on how to audit are in a 3 compliance supplement. Grants management guidance for nonprofit organizations. Omb circular a3, using techniques such as those discussed in the compliance requirements provisions of this section with the exception that these subrecipients are not required to have audits under omb circular a3. Governmental auditing standards and omb circular a3 update governmental auditing standards update sas no.
Subrecipient monitoring the responsibilities of passthrough. Guidance is not very explicit on the monitoring procedures that need to be performed, although it is clear monitoring is required. Percentage passed through if the subrecipient or program is determined to be high risk, the subrecipient monitoring procedures provides guidance for monitoring. The list must include the following information on each subrecipient name and address. Audits of states, local governments and nonprofit organizations imposes monitoring responsibilities on. These sections have been modified to include the new compliance requirements and suggested audit procedures relating to ffata. Oct 23, 2012 subrecipient monitoring the responsibilities of passthrough entities under omb circular a3 bruce morgan, assistant vice chancellor for research administration, university of californiairvine.
In addition, we have issued an unqualified opinion on the schedule of expenditures. Authorized signatures manual or electronic on eligibility documents periodically. Nonprofit, educational institution, or statelocal government entity uniform guidance, 2 cfr 200. The requirements for subrecipient monitoring are contained in 31 usc 7502 f2b single audit act amendments of 1996 pub. As defined by omb circular a3, a subrecipient relationship exists when funding from a passthrough entity is provided to perform a portion of the scope of work or objectives of the passthrough entitys award agreement with the awarding agency. Subrecipient monitoring procedures purdue university.
In other words, as found in the omb circular a3 compliance supplement, a subrecipient relationship. Subrecipients requests for federal funds are evaluated. The characteristics that define a subrecipient versus an entity that is just hired to perform services but isnt subject to compliance requirements called a vendor or a contractor remain unchanged. The payments received for goods or services provided as a would not be vendor considered federal awards. Awards programs, the district of columbia district is. The subrecipient does not have an annual a 3 audit 3. Ongoing monitoring builtin through independent reconciliations, staff meeting feedback, rotating.
Omb circular a3 do not constitute a subrecipient or. Federal awards expended by subrecipients are subject to audit under circular a3. Transfers of federal awards to another component of the same auditee under. Federal entity that receives a subaward from a pass. Findings on their most recent a3 audit report that relate to sponsored program activity 2. The payments received for goods or services provided as a would not be. A searchable copy of the cfda and a pdf version are available through the. Fact sheet broadband technology opportunities program. June 2015 compliance requirements compliance supplement 3.
Subrecipient monitoring sponsored projects and research. Single audit report under circular a3 louisvillejefferson county metro government for the fiscal year ended june 30, 2004. Passthrough entities are required to do the following. Auditors shall consider the compliance requirements and related audit objectives in part 3 and part 4 or 5 for programs included in this supplement in every audit conducted under omb circular a3 or 2 cfr part 200, subpart f, with the exception of programspecific audits performed in accordance with a federal agencys programspecific. Subrecipient monitoring describes any action taken by grantees throughout the life of a grant to ensure legal compliance and program performance. The rf omb circular a3 written notification of audit compliance letter or locationspecific letter containing the same information can be used.
Governmental auditing standards and omb circular a3. Omb circular a3 requires auditors to obtain an understanding of. Funding awarded prior to this date andor incremental funding may still be governed by omb circular a 110, a 21, or a 3, depending on the awarding agencys specific terams and conditions. Determining subrecipient eligibility in addition to any programmatic eligibility criteria. Assist university faculty and staff in the preparation and administration of subrecipient agreements issued under sponsored projects, 2. The omb circular a3 compliance supplement, chapter 6, provides a list of typical internal controls for subrecipient monitoring. The federal governments definition of a subrecipient is addressed in office of management and budget circular a3 omb a3, sections 105 and 210. The requirements that govern subrecipient monitoring are stated in omb circular no. Subrecipient monitoring under the ombs new super circular shawn miller originally posted. Subrecipient monitoring of federal grants maryland. Perform risk assessments to determine appropriate subrecipient monitoring.
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