ADMINISTRATIVE POLICY 5.6
Title & #: Subrecipient Monitoring on Federally Funded Subawards - 5.6 |
Executive Sponsor: Chief Financial Officer |
Date Effective: 08/18/2025 |
Supersedes Version: N/A |
Subrecipient Monitoring on Federally Funded Subawards
INDEX PURPOSE REASON FOR POLICY ENTITIES AFFECTED DEFINITIONS POLICY STATEMENT ROLES AND RESPONSIBILITIES COMPLIANCE AND TRAINING REQUIREMENTS EXCEPTIONS APPROVALS RELATED DOCUMENTS REVIEW AND REVISION HISTORY KCTCS will comply with the Office of Management and Budget (OMB) regarding our monitoring and stewardship obligations as an award recipient (prime or otherwise) when accepting federal funding and assigning responsibility for conducting a portion of the work to another entity through a subaward agreement pursuant to 2 CFR 200.332.
The individual(s) who oversees and manages the general operations, administrative, and strategic aspects of a specific college or business unit, ranging from daily operations to contributing to the overall success of the college or business unit. Grant Administrator The individual(s) that manages the grant lifecycle for a specific college or business unit, including identifying funding opportunities, preparing and submitting applications, managing awarded grants, and ensuring compliance with federal requirements. Pass-Through Entity A recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out part of a federal program. The authority of the pass-through entity under this part flows through the subaward agreement between the pass-through entity and subrecipient. Principal Investigator The individual responsible for activities on federally funded grant awards. Responsibilities include the intellectual conduct of the project, fiscal accountability, administration, and compliance. Subaward An award provided by a pass-through entity to a subrecipient for the subrecipient to contribute to the goals and objectives of the project by carrying out part of a federal award received by the pass-through entity. It does not include payments to a contractor, beneficiary, or participant. A subaward may be provided through any form of legal agreement consistent with criteria in with § 200.331, and KCTCS policy, including an agreement the pass-through entity considers a contract. Subrecipient An entity that receives a subaward from a pass-through entity to carry out part of a federal award. The term subrecipient does not include a beneficiary, contractor, or participant. Subrecipient Monitoring Activities undertaken to review financial status and management controls of a subrecipient to mitigate the risk of entering into an agreement with a subrecipient organization. This may include ongoing reviews to ensure compliance with said agreement. It is the policy of KCTCS to administer subawards consistent with the requirements of the OMB Uniform Guidance, and in accordance with the requirements of the institution, the applicable sponsor regulations, and the terms and conditions of the federal award. As the sponsored award recipient, KCTCS is responsible for ensuring performance goals are achieved and the scope of work is met while sponsor funds are managed appropriately. The goal is to ensure that the subaward satisfied institutional and governmental reviews as well as governmental audits.
Principal Investigators, along with applicable Grant and Business Administrators, are responsible for completing the required subrecipient monitoring on federally funded subawards. Enforcement of this policy and applicable procedures falls to the individual college or business unit. System oversight will be provided upon request of the individual college or business unit. Per 2 CFR 200.332, colleges are required to review and documents processes on an annual basis. Per 2 CFR 200.332, no exceptions are permitted within this process.
Code of Federal Regulations 2 CFR 200
Original Adoption – August 18, 2025. Next Scheduled Revision, on or before August 18, 2028. |