Subrecipient Policy: Difference between revisions

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POLICY NO: '''6108'''<br />

== Basis of the Policy ==

== Purpose of the Policy ==

   

As a condition of its acceptance of funding from sponsors, UNMC is obligated in its role as primary recipient to undertake certain stewardship activities as well as to comply with federal, state and local regulations.  When UNMC assigns responsibility for conducting a portion of the work sponsored by an award to a subrecipient, UNMC remains responsible to the sponsor for both the management of funds and the meeting of performance goals.  The purpose of this policy is to detail how UNMC will comply with these obligations<br /><br />

      

:Note: This policy does not include agreements for [[Vendors|vendors]], including items such as: consulting services or purchase orders for equipment, materials or other services, as explained below.

== Explanation of Key Concepts ==

      

* When UNMC receives a federal award, UNMC is considered the primary recipient (or “prime”) of the federal funds and the subrecipient is the organization that receives the subcontract from UNMC.

*    A subcontract creates no direct contractual relationship between the subrecipient and the awarding agency.

*        For example, if UNMC subcontracts part of an NIH award to another university, there is no contractual relationship between NIH and the other university.

      

=== Explanation of Vendors: ===

          

:Determination of whether the relationship is that of a subrecipient or a vendor is critical. OMB Circulars A-133 and A-110 contain definitions of vendor and subrecipient.  In summary:

              

* Vendors generally supply goods and services that are necessary to the completion of a project but are not part of a cooperative programmatic effort.  

It is the policy of UNMC to comply with federal regulations regarding subrecipient monitoring, when UNMC is the prime recipient of a federal award or contract.  The following are the key compliance requirements:

      

* Federal agencies clearly hold prime recipients responsible for establishing monitoring systems and controls to give reasonable assurance that subrecipients are in compliance with federal policies.  

Refer to the Subrecipient Monitoring Procedures for specific obligations and guidance.  

== Additional Information ==

      

* [http://www.unmc.edu/media/spa/subrecipientmonitoring.doc UNMC Subrecipient Monitoring Procedures]

Any questions about this policy should be referred to [http://info.unmc.edu/dept/fincompliance Financial Compliance and Cost Analysis].<br /><br />

This is a new UNMC policy.<br /><br />

Last Review by Policy Owner:  November 13, 2008.