Administrative Procedures

Subrecipient Monitoring on Federally Funded Subawards

Procedure Number 5.3.20-P                   Revision Number 0
Effective Date: 08/18/2025
Responsible Official: Government Affairs/Sponsored Projects Development Administration and Treasury/Sponsored Projects Accounting

 

1. Purpose

The Procedure provides business guidance in accordance with Administrative Policy 5.6 Subrecipient Monitoring on Federally Funded Subawards.

2. Scope

This Procedure applies to all KCTCS employees, students, colleges, offices, and workplaces, regardless of location and to all KCTCS-related conduct, policies, decisions, and actions.

3. Procedure

3.1 College and System Office Department Awardee Responsibility

1. The awardee college or department must complete monitoring of all federally funded programs in which a subrecipient relationship exists, as defined in 2 CFR 200.332.
   1. Subrecipient monitoring requires team effort involving the college grant officials, Sponsored Projects Development and Administration (SPDA) and Sponsored Projects Accounting (SPA). However, the primary responsible party is the Principal Investigator (PI). All subrecipient relationships are based on the availability of the federal funds.
      
      
2. The awardee college or department must first determine whether the subrecipient relationship exists rather than that of a contractor at the time of the project application.
   
   
3. Once the relationship is determined to be a subrecipient, the awardee college or department must complete a risk assessment for potential subrecipients to select the most applicable subrecipient.
   
   
4. Potential subrecipients must sign and complete the GC-6 form, along with submitting a statement of work, budget narrative, and budget. In addition to the GC-6, all potential subrecipients are required to complete a financial system assessment to ensure their ability to properly manage the federal funds.
   
   
5. After completing and returning the required documents, an agreement can be made between the awardee college or department and the subrecipient. The types of agreement can include Memorandums of Agreement (MOA) or Personal Services Contracts (PSC) depending on the financial structure of the subrecipient. Copies of the fully executed agreement and completed GC-6 must be forwarded to Sponsored Projects Accounting (SPA) for required federal reporting.
   
   
6. With a fully executed agreement in place, work commences. The awardee college or department is required to complete ongoing monitoring of the subrecipient to ensure that work completed aligns with the agreed upon scope of work. Monitoring can include accountability calls, desk/virtual reviews, or in-person reviews.
   1. Ongoing monitoring should occur no less than quarterly and no more than monthly. Records of the monitoring will be housed at the awardee college or department and subject to federal monitoring reviews.
      
      
7. On an annual basis, Sponsored Projects Accounting (SPA) will work with each subrecipient to complete a certification Uniform Guidance audit has been finalized, if applicable.