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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 sub-award. 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 sub-award (rather than a direct grant)?
- Is amount of sub-award more than $500k?
- Is amount of sub-award 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 sub-awards requiring management oversight beyond Management Level 1, appropriate monitoring actions will be taken to ensure compliance with sub-award performance, financial terms and conditions, sponsor requirements, and applicable State law, Federal law, rules, and regulations. (See Sub-award 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 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 sub-awards under the following circumstances:
- The administrative complexity or unique nature of the work performed under the sub-award 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 sub-award:
- is used for authorized purposes;
- is in compliance with statutes, regulations, and the terms and conditions of the sub-award; and
- performance goals are achieved.
- As part of sub-award 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 sub-award 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 sub-award;
- 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.