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Subrecipient Monitoring

Responsible Department
Grants & Contracts Administration
Effective Date
10/07/2019
  1. .

    Policy Purpose

    The purpose of this policy is to specify the University of North Georgia’s (the “University”) Grants and Contracts Administration responsibilities of its subcontractors/subawardees (“subrecipients”) to ensure optimal performance and proper stewardship of sponsored funds.

  2. .

    Definitions

    1. Contractor: An organization or individual that provides goods or services within normal business operations. Contractors (also known as vendors) may provide similar goods and services to many different purchasers, operate in a competitive environment, and provide goods and services that are ancillary to the operation of the sponsored project.

    2. Principal Investigator (PI):  The project director or lead investigator, identified by UNG, who is the programmatic point-of-contact on a project and is the primary person responsible for the design, conduct and/or reporting of sponsored activities undertaken by the University, funded or proposed for funding by an external sponsor, agency, or organization.

    3. Pass-through entity: The non-federal entity that provides a subaward to a subrecipient to carry out the program; sometimes referred to as “prime” or “lead” organization.

    4. Prime Recipient: The direct recipient of a sponsored award to support sponsored research, projects, or programs, as in this case, the University of North Georgia.

    5. Subaward (subcontract): Enforceable agreement, issued under a prime sponsored project, between a pass-through entity and a subrecipient for the performance of substantive portion of the project.  It is a written agreement with a third party for the acquisition of services and/or goods, or for the conduct of prescribed activities or functions under the prime award where the subrecipient has responsibility for programmatic decision making and measureable performance requirements related directly to the prime award. These terms do not apply to the procurement of goods or services from a contractor.

    6. Sponsor: Also referred to as the “funding Agency,” the agency providing the prime award agency that provided the prime award. The sponsor can be any type of public or private agency or organization.

    7. Sponsored award: A funding instrument with terms and conditions in which the University agrees to provide a return benefit to, or agrees to provide a defined deliverable(s) for a sponsor in exchange for funds. The funding instrument may be a grant, contract, cooperative agreement, or similar document.

    8. Subrecipient (subawardee): An organization that receives external funds from the University of North Georgia to carry out programmatic effort under a sponsored project where the University of North Georgia is the lead recipient of the external funding.  A subrecipient’s performance is measured against the objectives of the sponsored program. A subrecipient can be a public, non-profit entity, and must meet the eligibility determination for the sponsored project. The subrecipient can also be known as the collaborator or partner.
  3. .

    Policy Statement

    1. The Grants and Contracts Administration office monitors a number of processes to ensure that Principal Investigators effectively carry out their projects, including:

      1. Pre-award Process
      2. Post-award Process
      3. Subaward Amendments
      4. Carryover of Unobligated Balances
      5. Evaluating Subrecipient Risk Levels
      6. Close-out Subcontracts
      7. Monitoring Process
      8. Subaward Termination

    2. All Principal Investigators must comply with this policy and related procedures to ensure compliance.
  4. .

    Support Information

    The subrecipient monitoring policy is in compliance with applicable requirements in accordance with 2 CFR 200 Subpart D Subrecipient Monitoring and Management and Subpart F – Audit Requirements, when it is expected that the subrecipient’s federal awards expended during the respective fiscal year equals or exceed $750,000 (2 CFR 200.501).

  5. .

    Procedures

    Operating procedure implementation and oversight is the responsibility of Grants and Contracts Administration, a division of the Office of Research and Engagement.  Any related operating procedures must comply with and should reference this policy.

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