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OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards () (“Uniform Guidance”), specifically §200.331, requires pass-through entities (�鶹����P) to evaluate each subrecipient, and to monitor the activities of the subrecipient accordingly and in compliance with applicable Federal regulations and statutes.

A subrecipient agreement (subaward/subcontract) is an agreement made by the University to a third party for the performance of a substantive portion of the work of a sponsored project. In most cases, a subrecipient award will be for a particular phase or area of a sponsored project which has been identified in both the proposal and subsequent agreement of the prime award (grant or contract) and where the University maintains overall scientific, administrative, and financial responsibility (as opposed to covering the use of professional or consulting services).

In most cases, subrecipient agreements will be to other universities for services similar to those performed by the University (research, instruction, and public service).

Monitoring is a system of education, reviewing, tracking, and reporting on the use of grant
funds. Monitoring begins in the award phase and continues throughout all three phases in the life cycle of a grant.

Monitoring activities are designed to assure the public funds are spent in compliance with
applicable rules and statutes, and that performance expectations are being achieved. �鶹���� Pembroke is responsible for the programmatic and financial monitoring of its Sponsored Research and Programs, including all subrecipients.

Prior to the issuance of the subaward a risk assessment is conducted by the OSRP to determine the appropriate level of monitoring and to ensure monitoring and reporting requirements are
incorporated into the subaward document.

The assessment is conducted is conducted at the beginning of the project and annually thereafter unless circumstances warrant a more frequent assessment. The procedures outlined in the document below are intended to define specific responsibilities around award establishment and project monitoring as well as defining appropriate ways in which monitoring may be accomplished.