Embedded Files
In effort to ensure Federal compliance with regards to all restricted accounts, the ACC grant accounting department has provided the following Subrecipient Monitoring Procedures based on the Uniform Guidance:
What is a sub-recipient?
· Subrecipients are non-Federal entities that expend Federal awards received from a pass-through entity (ACC) in order to carry out a Federal program, but do not include an individual that is a beneficiary of such a program.
What are the requirements of ACC to the federal agencies by having sub-recipients?
· To provide reasonable assurance that Federal award information and compliance requirements are identified to sub-recipients, sub-recipient activities are monitored, sub-recipient audit findings are resolved, and the impact of any sub-recipient noncompliance on the pass-through entity is evaluated. Also, the pass-through entity should perform procedures to provide reasonable assurance that the sub-recipient obtained required audits and takes appropriate corrective action on audit findings.
What are the requirements of the sub-recipient?
· ACC access to financial records
- Chart of Accounts
- Manual on accounting procedures
- Accounting journals and ledgers
- Source documentation (purchase orders, invoices, canceled checks, etc.)
- Procurement files
- Bank account records
- Financial reports
- Comprehensive Annual Financial Report
Subrecipients monitoring procedures are as follows:
o Ensure that a signed sub-recipient agreement is in place.
o Check SAM.GOV to ensure the Subrecipient is not ineligible due to debarment or suspension.
o Have a kick-off meeting with sub-recipient to discuss the following:
o Identify the CFDA title and number, award name and number, award year and the name of the Federal agency.
o The guidelines and regulations of the grant, as well as, any supplemental requirements imposed by the pass-through entity (ie all invoices must have full backup documentation as part of the monitoring process).
o Ensure that sub-recipients expending $750,000 or more in Federal awards during the sub-recipient's fiscal year have met the audit requirements of Uniform Guidance Sub-part F for that fiscal year.
o Risk Assessment – each sub-recipient is evaluated on a yearly basis.
o The risk assessment will determine should a desk review and/or site visit be required.
o A monitoring letter will be emailed to the sub-recipient should a desk review and/or site visit be required.
o Site visits are determined based on the result of the risk assessment.
o Should a site visit be needed, ACC grant accounting will email the sub-recipient two weeks before the on-site visit with the list of items to be audited.
o Checklist/Verification requirements will be selected for review based on the risk assessment.
§ Sub-recipient Monitoring Form and Uniform Guidance Subpart F requirement received and signed.
§ Chart of accounts
§ Manual on accounting procedures
§ Accounting journal and general ledgers for grant accounts
§ Source documentation of invoices
§ Payroll Records
§ Procurement files
§ Internal controls
§ Bank account records
§ Monthly financials reports
§ Annual financial report or CAFR
§ Tax Report
o Document your monitoring
o Create an electronic folder on ACC’s network drive with all information regarding sub-recipient.
o Maintain a file or record of the desk reviews that you perform and the results.
o Document the follow-up work you perform on corrective action to be taken by sub-recipient.
o Document corrective action that is completed by the sub-recipient and any adjustments to their financial records or your records.
o Retain results of agreed-upon procedures.
o Upon completion of review/site visit, a Monitoring Completion Letter will be sent to Sub-recipient.
o Retain a copy of the management decisions you issued in response to sub-recipient audit findings.
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