In many cases, the sponsor allows the recipient of grant funds, the "prime awardee" or "grantee," to transfer a portion of the programmatic activity to another organization referred to as the "subrecipient." In such cases, SUU becomes the "pass-through" entity. The purpose of this policy and its supporting procedures are to provide oversight of subrecipients on federally sponsored programs as required by OMB Circular A-133.
As a pass-through entity subject to OMB A-133, Southern Utah University is responsible for performing the following actions for the Federal awards it makes to subrecipients:
- Identify Federal awards made by informing each subrecipient of CFDA title and number, award name and number, award year, if the award is R&D, and name of Federal agency. When some of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award;
- Advise subrecipients of requirements imposed on them by Federal laws, regulations, and the provisions of contracts or grant agreements as well as any supplemental requirements imposed by the pass-through entity;
- Monitor the activities of subrecipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved;
- Ensure that subrecipients expending $300,000 ($500,000 for fiscal years ending after December 31, 2003) or more in Federal awards during the subrecipient's fiscal year have met the audit requirements of this part for that fiscal year;
- Issue a management decision on audit findings within six months after receipt of the subrecipient's audit report and ensure that the subrecipient takes appropriate and timely corrective action;
- Consider whether subrecipient audits necessitate adjustment of the pass-through entity's own records;
- Require each subrecipient to permit the pass-through entity and auditors to have access to the records and financial statements as necessary for the pass-through entity to comply with this part.