Steve Martin, Associate Vice President for Research
This policy applies to all federal and federal flow through Subawards issued under sponsored awards made to Indiana University. This is intended for use by principal investigators, department administrators, and the Office of Research Administration (ORA) to define their respective roles and responsibilities for Subrecipient monitoring. This policy does not apply to consultant agreements or the procurement of goods and services from vendors.
It is the policy of Indiana University to administer subawards consistent with the requirements of Office of Management and Budget (OMB) federal regulation 2 CFR part 200 “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”, and in accordance with University policies, the applicable sponsor regulations, and the terms and conditions of the Prime Award. As the Prime Recipient, the University remains responsible for the management of funds and meeting performance goals when issuing Subawards.
As a recipient of federal sponsored awards, Indiana University must comply with the Office of Management and Budget federal regulation 2 CFR part 200 “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards” and any future applicable circulars. In addition, Indiana University must comply with the Subrecipient monitoring requirements specifically contained in the following:
As a condition of award acceptance, the University is obligated to monitor the work of any Subrecipients, including ongoing verification of the following:
In addition, the University must ensure that Subrecipients meet the audit requirements in CFR part 200 and use funds in accordance with applicable laws, regulations and terms of the award.
Department and Principal Investigator Responsibilities:
Office of Research Administration Responsibilities:
Corrective Action Plan: At the completion of an audit, an auditee prepares this document, separate from the auditor’s findings, that provides the following: the name of the contact person responsible for the corrective action, the corrective action planned for each audit finding included in the current year auditor’s reports, and the anticipated completion date.
CFDA Number: The Catalog of Federal Domestic Assistance number, which identifies the funding program for federal assistance awards.
DUNS Number: The Data Universal Numbering System (DUNS) number which is a unique nine-digit identification number provided by the company Dun & Bradstreet.
FAR: The Federal Acquisition Regulation clauses that are applicable to federal contracts.
FFATA Reporting: The Federal Funding Accountability and Transparency Act which requires Prime Recipients to report Subawards.
2 CFR Part 200: An OMB publication in the Code of Federal Regulations entitled “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.”
Prime Award: The award mechanism for the direct recipient of sponsored project funds.
Pass-through Entity (Prime Recipient): The direct recipient of sponsored project funds.
SAM: The System for Award Management, in which an entity must be registered if it wishes to do business with the federal government under contracts, grants, cooperative agreements or other forms of federal financial assistance.
Scope of Work: A document that captures and defines work activities, deliverables and timelines for work to be completed under a sponsored project.
Sponsor: The funding agency for sponsored project funds.
Subrecipient: The recipient of sponsored project funds from a Pass-through Entity.
• performance is measured against the objectives of the federal program
• has responsibility for programmatic decision making
• is responsible for adherence to applicable Federal compliance requirements
• does not provide goods or services for the program
• is usually another higher education institution, hospital, or other non-profit organization
• provides goods and services within normal business operations
• provides similar goods or services to many different purchasers
• operates in a competitive environment
• provides goods or services ancillary to the Federal program
• is not subject to the compliance requirements of the Federal program
• is usually a company or may be an individual
In the event there are audit findings which relate to the funding provided by Indiana University under any Subawards, the department would be responsible for repaying any disallowed cost that cannot be recovered by the Subrecipient.
Violations of university policies, including the failure to avoid a prohibited activity or obtain required approvals, will be dealt with in accordance with applicable university policies and procedures. Depending on the individual and circumstances, such sanctions could involve the offices of Human Resources, Vice Provost or Vice Chancellor of Faculties (or campus equivalent), Dean of Students (or campus equivalent), Office of the General Counsel, and/or appropriate law enforcement agencies.