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  • Mandatory list of standard data elements required to be included in an subaward. 

  • Subrecipient monitoring responsibilities increase as a result of Uniform Guidance - limit moved from $500 - $750K for a single audit and review of performance reports. 
  • Sponsors are obligated to honor subrecipient's negotiated F&A rate. The University is also required to honor all subrecipient negotiated F&A rates on federally funded subawards. If the subrecipient does not have a negotiated rate, then the de minimus indirect cost rate of 10% should be applied unless otherwise negotiated.

  • Subaward must include any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any financial and performance reporting

  • Must be able to track subrecipient technical and financial reports (dates received and reviewed), how deficiencies are addressed and how reports are stored.

Action Plan

  • Verify our existing internal review processes in place for subrecipients risk assessment considers whether the subrecipient has new personnel or new or substantially changed systems. (Anthony Adamczyk, Becky Thatcher)
  • Add reporting requirements to the subaward template if not included in FDP template. (Anna Marie Dawley)
  • The FDP is updating their subaward documents. We intend to use these documents (as we currently do today). Once they are published, we will review these updated documents and identify any Clarkson specific modifications that are needed. (Anthony Adamczyk)
  • Review current subrecipient invoice process and forms. Verify process and language meets the requirements of the new Uniform Guidance (regarding the certification from PI stating that subrecipient performance goals and reports have been received, reviewed, and that there is concurrence that they met the requirements). (Anthony Adamczyk, Becky Thatcher)






  • Waiting for updated FDA templates and evaluation. 
  • Reviewing internal processes.