Eliminate Prime Recipient Monitoring of Subs Subject to Audit

AAU, COGR and APLU recommend that OMB clarify that where a subrecipient has a current Single Audit report, prime recipients can rely on the subrecipient’s auditors and cognizant agency oversight for routine audit follow-up and management decisions.

Science is engendering an increased number of collaborative projects, resulting in significant growth in the number of subawards issued and received by institutions of higher education. The Uniform Guidance has added prescriptive administrative requirements (e.g., determination of subrecipient/contractor relationship (implied need to document for audit purposes) and detailed risk assessment and monitoring requirements) to an already burdensome process of issuing subawards to other universities and research organizations for collaborations on federally funded projects. With subrecipient monitoring, the “Prime” recipient is expected to monitor the business practices and internal controls of the subrecipient. This may be necessary for subrecipients that do not meet the threshold for Federal Single Audit ($750K in 2 CFR 200).It is unnecessary for subrecipients that have completed a Federal Single Audit.

The vast number of our subrecipients are our sister universities. There is no added benefit in University #1, the prime recipient of federal funds, monitoring University #2, the subrecipient, for compliance with audit requirements when Universities #3 – #50, also prime recipients, are also monitoring University #2, their subrecipient. And all this is in addition to the monitoring of University #2 that is being conducted by several Federal funding agencies. Subrecipient monitoring is a costly practice that has persisted, for unknown reasons, despite consistent calls to eliminate it.

In response to a recent AAU-COGR-APLU survey, 51 institutions reported:

• 3,578 subrecipients with federal awards not subject to an A-133 audit in FY14, but

• 8,409 subrecipients with federal awards were subject to A-133 audit in FY14.

• An average of 2.8 FTE dedicated to subrecipient monitoring; the fully burdened cost of such staff was $7,524,944 (for the 51 institutions) in FY14. (Central staff only; excludes investigators and departmental staff.) Institutions anticipate adding staff/FTEs to comply with the new requirements specified in § 200.331(d) of the Uniform Guidance.

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Contractors and Grantees
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Reporting compliance requirements shared by prime and subawardees of Federal procurements and grants
Key Participants: contractors, grantees, cooperative agreement holders, and subawardees
- Question: If you could change one thing that would ease your reporting burden associated with your awards, what would it be (e.g. time, cost, resource, other)?
- Question: If you have reporting requirements to the Federal government, how are those met?
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities or functions would you include?
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Contractors
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Procurement practices, processes, and reporting
Key Participants: Contractors and subcontractors
- Question: If you could change one thing that would ease your reporting burden associated with your awards, what would it be (e.g. time, cost, resource, other)?
- Question: If you have reporting requirements to the Federal government, how are those met?
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities or functions would you include?
- Question: Are there any reporting areas in the FAR that are similar in nature to those in Federal agency supplements?
- Question: What other compliance information are you providing to the Federal government outside of the procurement process that could be used in procurement reporting and reduce duplication?
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Grantees
*To participate in the dialogue, you can submit a new idea by clicking "Submit New Idea" to the right, or you can vote and comment on existing ideas below.

Grants practices and processes
Key Participants: grantees, cooperative agreement holders, subgrantees
- Question: If you could change one thing that would ease your reporting burden associated with your grants or subgrants, what would it be (e.g., time, cost, resource burden)?
- Question: If you have reporting requirements to the Federal government, how are those met? (feel free to be specific about what is reported to whom and through what mechanism)
- Question: If you could create a central reporting portal into which you could submit all required reports, what capabilities/functions would you include?
OMB circular A-133:
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditee?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting by the auditor?
- Question: If you could make a change to ease your reporting burden for audits under the Single Audit Act (i.e., audits required by OMB Circular A-133 which is being replaced by the Uniform Guidance 2 CFR 200 Subpart F), what one thing would you change about reporting to the Federal Audit Clearinghouse?
Uniform Guidance (2 CFR 200):
- Question: Are there requirements in the new 2 CFR 200 that need additional clarification for improved implementation with reduced administrative burden ?
- Question: What are the perceived burdens associated with the new standards such as the documentation of salaries & wages and time & effort (2 CFR 200.430), subrecipient monitoring (2 CFR 200.331), procurement standards (2 CFR 200.317- 2 CFR 200.324)?
- Question: How can the administrative burden associated with standards compliance be lowered?
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