Subrecipient Monitoring and Engagement

Detail a plan for monitoring the delivery of family planning services under the Title X project, including the monitoring and oversight of subrecipients. (45 CFR § 75.352)

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Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the required information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the recipient (i.e., pass-through entity) must provide the best information available to describe the Federal award and subaward. As noted in 45 CFR § 75.352, the required information includes:

1. Federal Award Identification:
   1. Subrecipient name (which must match the name associated with its unique entity identifier;
   2. Subrecipient's unique entity identifier;
   3. Federal Award Identification Number (FAIN);
   4. Federal award date (see § 75.2 federal award date) of award to the recipient by the HHS awarding agency;
   5. Subaward period of performance start and end date;
   6. Amount of federal funds obligated by this action by the recipient to the subrecipient;
   7. Total amount of federal funds obligated to the subrecipient by the recipient including the current obligation;
   8. Total amount of the federal award committed to the subrecipient by the recipient;
   9. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA);
   10. Name of HHS awarding agency, recipient, and contract information for awarding official of the recipient;
   11. CFDA number and name; the recipient must identify the dollar amount made available under each federal award and the CFDA number at time of disbursement;
   12. Identification of whether the award is R&D; and m. Indirect cost rate for the federal award (including if the de minimis rate is charged per § 75.414).
2. All requirements imposed by the recipient on the subrecipient so that the federal award is used in accordance with federal statutes, regulations and the terms and conditions of the federal award.
3. Any additional requirements that the recipient imposes on the subrecipient in order for the recipient to meet its own responsibility to the HHS awarding agency including identification of any required financial and performance reports.
4. An approved federally recognized indirect cost rate negotiated between the subrecipient and the federal government or, if no such rate exists, either a rate negotiated between the recipient and the subrecipient (in compliance with 45 CFR Part 75), or a de minimis indirect cost rate as defined in § 75.414(f).
5. A requirement that the subrecipient permit the recipient and auditors to have access to the subrecipient's records and financial statements as necessary for the recipient to meet the requirements of 45 CFR Part 75.
6. Appropriate terms and conditions concerning closeout of the subaward.

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Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring in accordance with 45 CFR § 75.352(d) and (e). (45 CFR § 75.352(b))

Note: This expectation is not part of the OPA Title X program review. This is assessed by the Office of Grants and Acquisition Management.

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Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in 45 CFR § 75.207. (45 CFR § 75.352(c))

Note: This expectation is not part of the OPA Title X program review. This is assessed by the Office of Grants and Acquisition Management.

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In accordance with 45 CFR § 75.352(d), monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Recipient monitoring of the subrecipient must include:

1. Reviewing financial and performance reports required by the recipient.
2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the recipient detected through audits, on-site reviews, and other means.
3. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the recipient as required by 45 CFR § 75.521.

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Depending upon the recipient’s assessment of risk posed by the subrecipient, employ the following monitoring tools that may be useful for the recipient to ensure proper accountability and compliance with program requirements and achievement of performance goals: providing subrecipients with training and technical assistance on program-related matters; and performing on-site reviews of the subrecipient's program operations; and arranging for agreed-upon-procedures engagements as described in 45 CFR § 75.425. (45 CFR § 75.352(e))

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Verify that every subrecipient is audited as required by Subpart F of 45 CFR Part 75 when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 45 CFR § 75.501. (45 CFR § 75.352(f))

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Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the recipient’s own records. (45 CFR § 75.352(g))

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Consider taking enforcement action against noncompliant subrecipients as described in 45 CFR § 75.371 and in program regulations. (45 CFR § 75.352(h))

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Provide that if an application relates to consolidation of service areas or health resources or would otherwise affect the operations of local or regional entities, the applicant must document that these entities have been given, to the maximum feasible extent, an opportunity to participate in the development of the application. Local and regional entities include existing or potential subrecipients which have previously provided or propose to provide family planning services to the area proposed to be served by the applicant. (42 CFR § 59.5(a)(11)(i))

Note: This expectation is not assessed during the OPA Title X Program Review.

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Provide an opportunity for maximum participation by existing or potential subrecipients in the ongoing policy decision making of the project. (42 CFR § 59.5(a)(11)(ii))

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