Subrecipient Monitoring on Federally Funded Subawards | KCTCS

Administrative Policies

Subrecipient Monitoring on Federally Funded Subawards

Policy Number: 5.6

Current Effective Date: 08/18/2025

Original Effective Date: 08/18/2025

Revision Dates: 0

Revision Number: 0

Revision Summary: implementation of new policy

Responsible Official: Chief Financial Officer

References:

I. Purpose

KCTCS will comply with the Office of Management and Budget (OMB) regarding our monitoring and stewardship obligations as an award recipient (prime or otherwise) when accepting federal funding and assigning responsibility for conducting a portion of the work to another entity through a subaward agreement pursuant to 2 CFR 200.332.

II. Reason for Policy

As the recipient of a federally funded grant award, which includes one or more outgoing subawards to other entities, KCTCS has the responsibility of ensuring that all work on the award is conducted and administered in compliance with sponsor requirements and KCTCS policies. Subrecipient monitoring includes activities undertaken to review the financial status and management controls of a subrecipient to mitigate the risk of entering into an agreement with the subrecipient organization.

III. Entities Affected

This policy applies to federally funded subawards issued under federally sponsored awards made to KCTCS. The corresponding procedures are intended for use by Principal Investigators, Grant Administrators, and Business Administrators. This policy does not apply to other forms of vendor procurement.

IV. Definitions

  1. Business Administrator
    The individual(s) who oversees and manages the general operations, administrative, and strategic aspects of a specific college or business unit, ranging from daily operations to contributing to the overall success of the college or business unit.

  2. Grant Administrator 
    The individual(s) that manages the grant lifecycle for a specific college or business unit, including identifying funding opportunities, preparing and submitting applications, managing awarded grants, and ensuring compliance with federal requirements.

  3. Pass-Through Entity 
    A recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out part of a federal program. The authority of the pass-through entity under this part flows through the subaward agreement between the pass-through entity and subrecipient.

  4. Principal Investigator 
    The individual responsible for activities on federally funded grant awards. Responsibilities include the intellectual conduct of the project, fiscal accountability, administration, and compliance.

  5. Subaward 
    An award provided by a pass-through entity to a subrecipient for the subrecipient to contribute to the goals and objectives of the project by carrying out part of a federal award received by the pass-through entity. It does not include payments to a contractor, beneficiary, or participant. A subaward may be provided through any form of legal agreement consistent with criteria in with § 200.331, and KCTCS policy, including an agreement the pass-through entity considers a contract.

  6. Subrecipient 
    An entity that receives a subaward from a pass-through entity to carry out part of a federal award. The term subrecipient does not include a beneficiary, contractor, or participant.

  7. Subrecipient Monitoring 
    Activities undertaken to review financial status and management controls of a subrecipient to mitigate the risk of entering into an agreement with a subrecipient organization. This may include ongoing reviews to ensure compliance with said agreement.

V. Policy Statement

It is the policy of KCTCS to administer subawards consistent with the requirements of the OMB Uniform Guidance, and in accordance with the requirements of the institution, the applicable sponsor regulations, and the terms and conditions of the federal award. As the sponsored award recipient, KCTCS is responsible for ensuring performance goals are achieved and the scope of work is met while sponsor funds are managed appropriately. The goal is to ensure that the subaward satisfied institutional and governmental reviews as well as governmental audits.

VI. Roles and Responsibilities

Principal Investigators, along with applicable Grant and Business Administrators, are responsible for conducting initial and ongoing monitoring of federally funded subawards. Failure to adhere to these federal regulations in connection with a specific subrecipient monitoring may result in a loss of current funding and/or future funding opportunities.

VII. Compliance and Training Requirements

The Office of Sponsored Projects Accounting, in conjunction with the Office of Sponsored Projects Development and Administration, will prepare and provide training on an as needed basis to applicable Principal Investigators, Grant Administrators, and Business Administrators.

Principal Investigators, along with applicable Grant and Business Administrators, are responsible for completing the required subrecipient monitoring on federally funded subawards. Enforcement of this policy and applicable procedures falls to the individual college or business unit. System oversight will be provided upon request of the individual college or business unit.

Per 2 CFR 200.332, colleges are required to review and documents processes on an annual basis.

VIII. Exceptions

Per 2 CFR 200.332, no exceptions are permitted within this process.

IX. Approvals

Approved by KCTCS President, Dr. Ryan Quarles on August 18th 2025

X. Related Documents

OMB Uniform Guidance

Code of Federal Regulations 2 CFR 200

XI. Review and Revision History

This policy shall be reviewed every three (3) years from the date of the original adoption. 

Original Adoption – August 18, 2025

Next Scheduled Revision, on or before August 18, 2028.