OMB circular A-133-Subrecipient

Subrecipient monitoring requires recipients to monitor the activities of subrecipients relative to their federal awards.

An award recipient is responsible for:

• At the time of the award, identifying to the subrecipient the federal award information (e.g., CFDA title and number, award name, name of federal agency) and applicable compliance requirements.
• Monitoring the subrecipient's use of federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers federal awards in compliance with the laws, regulations, and provisions of contracts or grant agreements and that performance goals are achieved.
• Subrecipient Audits - (1) Ensuring that subrecipients expending $500,000 or more in federal awards* during the subrecipient's fiscal year for fiscal years ending after December 31, 2003 as provided in OMB Circular A-133 have met the audit requirements of OMB Circular A-133 (the circular is available on the Internet at http://www.whitehouse.gov/omb/circulars/a133/a133.html) and that the required audits are completed within nine (9) months of the end of the subrecipient's audit period. (2) Issuing a management decision on audit findings within six (6) months after receipt of the subrecipient's audit report. (3) Ensuring the subrecipient takes timely and appropriate corrective action on all audit findings. In cases of continued inability or unwillingness of a subrecipient to have the required audits, the pass-through entity shall take appropriate action using sanctions. 
• Evaluating the impact of subrecipient activities on the pass-through entity's ability to comply with applicable federal regulations.

* This threshold includes both the subaward in question and all other federal awards, both direct and indirect.

Monitoring activities normally occur throughout the year and may take various forms, such as:

• Reporting - Reviewing financial and performance reports submitted by the subrecipient.
• Site Visits - Performing site visits at the subrecipient to review financial and programmatic records and observe operations.
• Regular Contact - Regular contact with subrecipients and appropriate inquiries concerning program activities.