To sum up how many people feel about subrecipient monitoring, you can’t do much better than to just say, it’s a big pain in the you-know-what. There are regulations to follow, subcontractors to keep tabs on, money to allocate and plenty of risks to manage. But when institutions combine forces, the potential for collaboration and scientific breakthroughs can often be enough outweigh all those frustrations — especially when the institutions are equipped with a few tools to make things go smoother.
Subrecipient awards are given when a primary recipient receives federal research funds for a project and decides to contract them out to other institutions. The federal government, in turn, requires that all primary recipients keep tabs on their contractors to make sure funds are being used properly and for research only.
Subrecipient awards management really only came about in the last decade, as a result of several major incidents in which subrecipients improperly used federal funds. In some cases, the funds were misspent on things like unapproved equipment or expenses not related to a study, and in other cases, investigators committed fraud and theft.
Managing subrecipient awards may seem daunting at first, but with a little prep work and organization, the whole process can be made seamless. The first step to establishing a smooth monitoring process is to find the most updated federal regulations from the organization awarding your grant. The government has continued to increase the amount of monitoring they require from the institutions, so regulations and practices are always changing—keep an eye on them.
Once you’ve familiarized yourself with what you’re expected to monitor and how you’re expected to do it, you’ll want to start collecting A-133 forms from prospective subrecipients. An A-133 is an audit of institutions that receive $500,000 or more in federal research funding. It signifies that an auditor has checked to make sure an institution has the necessary business practices and controls in place to ensure funds security. The government and primary recipients use it as a check to assess the risks involved in granting a subcontract.
If there are big enough problems with an institution’s A-133, a subcontract is high risk and needs to be monitored very closely through documentation, site visits, deliverables and communication if the contract is granted. On the other hand, clean A-133s are much lower risk. If you can choose an institution with a clean A-133 you’ll save yourself a lot of trouble.
Of course, another helpful move that your institution can make for the subrecipient awards management process is to invest in electronic research administration software. In our Research Suite, for example, Cayuse424 uses Subawards.com to prepare and share subawards proposals directly between institutions. Having your subaward documentation in the cloud is particularly helpful for collaborating between institutions. In addition, with Cayuse SP institutions can to store information about subawardees securely so that audits, deliverables, correspondence and notes in one place to ensure the process is transparent.
In terms of keeping track of your subrecipients during the monitoring process, you’ll want to first make sure the terms and conditions of a subcontract are discussed beforehand. This is your chance to address what money can and cannot be spent on, as well as to outline expectations. Check in with your subcontractors as the project progresses through emails, expense reports, progress updates and deliverables.
While subrecipient awards management is, without question, a lot of work, with the right preparation, it doesn’t have to cause headaches. Now that you know what you’re getting into, you’re already starting off ahead.
Tell us: What other practices do you have at your institution to make it easier to manage subcontracts? What has and hasn’t worked?