We have noticed that one of the most common OMB A-133 findings is failure to adequately monitor subcontractors.  This is also required of DoD contractors.

Recipients are responsible for ensuring that subrecipients comply with all requirements associated with the federal assistance that are applicable to recipients.

Recipients are responsible for:

1. Monitoring subrecipients’ use of Federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers the Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements and performance goals are achieved.
2. Identifying to first-tier subrecipients the requirement to register in the Central Contractor Registration, including obtaining a Dun and Bradstreet Data Universal Numbering System (DUNS) number, and maintaining the accuracy of that information.

The Recipient should develop subrecipient monitoring policies and procedures (e.g. annual monitoring plan).  The monitoring plan should include the following components:

1. Documentation of pre-award check that subrecipient is registered with CCR.
2. Procedures for notifying subrecipients of key elements of the award:
   1. CFDA title and number
   2. Award name and number
   3. If the award is research and development
   4. Name of Federal awarding agency
   5. Requirements imposed by laws, regulations, and the provisions of contract or grant agreements
   6. The activities approved in the award documents were allowable.
3. Documentation of monitoring activities during-the-award period.

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Related posts:

1. SBIR 301-1: OMB A-133 Accounting System Requirements
2. SBIR 301-2: SBIR Subcontracting Responsibilities
3. Government Contracting and Accounting 101 – ITAC & Jameson CPA Team Up this May 7th

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