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Sub-Recipient Management, Assessment & Monitoring Classification
Management Level Determination
The following factors are illustrative of those used to determine the management level appropriate for a sub-recipient. These assessment factors may be expanded as dictated by the nature of the work to be performed and the proposed sub-recipient’s performance history and management capacity.
The following questions will be used by OSP to facilitate the establishment of the appropriate management level for each subaward. As part of OSP’s analysis, the questions are weighted to address the significance of the management issue.
- Is the sub-recipient located outside the U.S.?
- Will work be done outside the U.S. by sub-recipient?
- Is sub-recipient work export controlled?
- Is sub-recipient a non-profit or government entity?
- Is prime award a contract or subaward (rather than a direct grant)?
- Is amount of subaward more than $500k?
- Is amount of subaward 50% or more of total WVU/WVURC award?
- Does the sub-recipient have an established accounting system?
- Do audit results indicate weaknesses in the sub-recipient's procurement system?
- Does sub-recipient have a negotiated indirect cost rate agreement?
- Is sub-recipient subject to OMB Uniform Guidance?
- Is the sub-recipient using humans, animals, DNA, stem cells, etc.?
- Is the sub-recipient administratively mature?
- Is prime sponsor government owned & contractor operated?
- Is there potential for COI regarding relationship between sub-recipient and WVU/WVURC PI/PD?
- Are deliverables or tangible products pivotal to success?
- Is "Advantaged" status claimed?
- Is the administrative relationship between the sub-recipient and WVU/WVURC positive?
After an evaluation of the above criteria, and upon identification of subawards requiring management oversight beyond Management Level 1, appropriate monitoring actions will be taken to ensure compliance with subaward performance, financial terms and conditions, sponsor requirements, and applicable State law, Federal law, rules, and regulations. (See Subaward Management section, below.)
In addition to routine monitoring procedures, OSP will work with WVU/WVURC PI/PDs and school/department administrators to establish channels of communication with sub-recipients where expanded oversight is necessary.
Management Levels
Management Level 1 (ML1) – includes those sub-recipients that require general monitoring, only. (See General Monitoring Requirements, below)
Management Level 2 (ML2) – will be assigned to subawards under the following circumstances:
- The administrative complexity or unique nature of the work performed under the subaward warrants extraordinary administrative reviews, documentation, certifications, etc.;
- The work is determined to be governed by U.S. export control law and regulations;
- The work is to be performed outside of the United States;
- Prior administrative history between WVU/WVURC and sub-recipient is problematic; or
- The management systems or award management experience of a sub-recipient are deficient.
In addition to obligations under ML1, ML2 sub-recipients may be required to provide additional information to enable WVU/WVURC to document sub-recipient internal controls and management procedures and to otherwise assure compliance with sponsor requirements.
General Monitoring Requirements (Management Level 1)
WVU/WVURC will monitor the activities of the sub-recipient, as necessary, to ensure that the subaward:
- is used for authorized purposes;
- is in compliance with statutes, regulations, and the terms and conditions of the subaward; and
- performance goals are achieved.
WVU/WVURC will:
- As part of subaward close-out, monitor the submission of sub-recipient reports;
- Follow-up and ensure that the sub-recipient takes timely and appropriate action on all deficiencies pertaining to the subaward as determined through audits, on-site reviews, and the evaluation of business transactions and commonly accepted business practices;
- Issue management decisions to sub-recipient for audit findings pertaining to the subaward;
- Verify through the Cost/Compliance Accounting unit within Financial Services that every sub-recipient is audited as required by sponsor;
- In conjunction with the Cost/Compliance Accounting unit, consider whether the results of the sub-recipient’s audits, on-site reviews, or other monitoring activities indicate conditions that necessitate financial adjustments; and
- After all due consideration, take corrective action against noncompliant sub-recipients.
Management Level 2 (ML2) Monitoring Requirements
In addition to the monitoring requirements set forth in ML1, ML2 monitoring requirements will be tailored to the circumstance(s) that dictated the need for enhanced monitoring.