Subaward Administration at CSU –Subrecipient Risk Assessment
Per federal guidance (2 CFR § 200.331b), OSP evaluates each subrecipient’s risk of non-compliance with federal regulations and subaward terms and conditions. Factors may include:
- the subrecipient’s prior experience with the same or similar subawards;
- the results of previous audits or if not subject to annual audit, a review of their annual financial statements;
- whether the subrecipient has appropriate accounting systems in place to manage sponsored funds; and
- the extent and results of federal agency monitoring.
The OSP Subaward Team performs an annual review of a subrecipient’s single audit or financial records to evaluate risk, treating all subrecipient risk assessments consistently across funding source (federal and non-federal). For CSU, examples of high-risk subrecipients may include:
- Entities outside the U.S. or European Union
- Small businesses or start-up companies
- Subrecipients with audit findings
If the subrecipient is deemed by OSP to be high risk, additional oversight may be required throughout the life of the subaward which may include issuing a fixed-price budget, special invoicing instructions, or corrective action plan for high-risk areas.
If you suspect a subrecipient may be high-risk, work with your OSP RA or OSP Subaward Team to ensure appropriate measures are in place, such as issuing a task-based, fixed price agreement or requiring additional subrecipient monitoring.
When in doubt, contact the OSP Subaward Team.
Blog post by Tricia Callahan, Senior Research Education and Information Officer, and Kris Miller, Subaward Manager, Office of Sponsored Programs