| Office of Sponsored Programs |
In March 2003, the Office of Management and Budget (OMB) issued a revision to the A-133 Compliance Supplement Attachment M “Subrecipient Monitoring”.
There were significant changes that call for stringent up-front subrecipient reviews as well as on-going subrecipient monitoring requirements. The changes have a greater effect with respect to commercial subrecipients than to educational institutions or other A-133 entities.
As a result of thesechanges, the OSP Research Subawards Office may need to conduct a risk analysis on some potential subrecipients to determine if the subrecipient can administer a federal award in compliance with the (federal) requirements. Based on the results of the subrecipient risk analysis, MIT may need to do a pre-award audit, or a pre-award accounting survey or a site visit.
This may impact the timing of the release of the subrecipient agreement. Consequently, it would be advisable for the DLC’s to notify the Research Subawards Office as soon as possible when a large dollar award to a commercial recipient is anticipated.
The other major change involves monitoring the subrecipient’s progress. Per the March 2003 Attachment M Compliance Supplement:
“Monitoring activities normally occur throughout the year and may take various forms, such as:
- Reporting - Reviewing financial and performance reports submitted by the subrecipient.
- Site Visits - Performing site visits at the subrecipient to review financial and programmatic records and observe operations.
- Contact - Regular contacts with subrecipients and appropriate inquiries concerning program activities.”
We are currently reviewing and monitoring the subrecipient’s
progress per the
OSP RSO Invoice Management program. We are currently considering other monitoring
tools such as:
Quarterly financial/technical progress reports
Possible site visits
Reviewing annual Subrecipient A-133 Audits reports
Once OSP completes the review of the Supplement Attachment M changes and the current MIT subrecipient policies and procedures, we will notify the DLC’s of any significant changes.
The full text of the OMB clarification can be accessed at the following OMB website: http://www.whitehouse.gov/omb/grants/grants_circulars.html
Last updated 6/25/03