Finding Text
2024-002 Subrecipient Monitoring
Research and Development Cluster:
National Institutes of Health:
Allergy and Infectious Diseases Research (ALN 93.855)
Statistically valid sample: No, and it was not intended to be.
Repeat finding: Not a repeat finding.
Finding Type: Noncompliance and Significant Deficiency
Criteria:
A pass-through entity is required to evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the subrecipient’s prior experience with similar subawards, whether the subrecipient has new personnel or new or substantially changed systems and the extent and results of federal awarding agency monitoring. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that transactions are executed in compliance with federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a federal program.
Condition and context:
Prior to executing a subaward, the University performs a risk assessment over the potential subrecipient to evaluate the risk of noncompliance with federal statues, regulations, and the terms and conditions of the subaward by the subrecipient. This risk assessment includes the review of a commitment form. The commitment form is prepared by the subrecipient and reviewed by the Principal Investigator and includes an evaluation of the results of previous audits, whether the subrecipient has new personnel or new or substantially changed systems and the extent and results of federal awarding agency monitoring.
We selected seven subrecipients out of a population of 50 subrecipients for test work who had subaward agreements with the University during the fiscal year 2024 and noted for two subrecipients, the commitment form was not received and reviewed prior to the University entering into the subawardee agreement.
Cause:
The Principal Investigators did not obtain the commitment forms from two subrecipients and therefore, could not provide evidence that a risk assessment was performed prior to the University entering into the subaward.
Effect:
The University could provide a subaward to a subrecipient that is considered to have a higher risk of noncompliance and require additional monitoring, and not perform that additional monitoring.
Questioned Costs:
None.
Recommendation:
The University should strengthen its policies and procedures over its subrecipient monitoring process over the Research and Development Cluster programs and provide training to the staff responsible for this federal requirement to ensure all necessary documentation is received and reviewed in accordance with the University's policies and procedures.
Views of Responsible Officials:
As of March 2021, Rockefeller University’s Office of Sponsored Programs Administration (OSPA) requires collection of the subrecipient commitment form for all applications including outgoing subawards, regardless of FDP Clearinghouse or membership status. All OSPA staff have been trained on this requirement, and we continue to emphasize this requirement in our team meetings. In addition, the requirements were sent to the university community in March 2021 and posted on the OSPA website. If a university applicant resists this requirement, all OSPA staff are required to forward that information to the Director, who communicates the requirement to the applicant. OSPA will be re-educating the laboratories on this requirement in the coming weeks via email and will repeat on a semi-annual basis.