I'm a bit late in responding to your inquiry, but the Federal Demonstration Partnership has a nice risk assessment tool you can utilize to determine the level of risk in collaborating with a subrecipient.  You can find this at thefdp.org.

Bobbie Ursin
Research Administrator
Southern Utah University
________________________________________
From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> on behalf of Hoffman, Ann <xxxxxx@MSU.EDU>
Sent: Friday, October 18, 2019 9:35:54 AM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: Re: [RESADM-L] High Risk Subawards

Hello Megan,

“Low-risk” institutions follow what we think of as best post-award practices.  They follow accepted cost accounting principles, have financial internal controls, human subjects and animal assurances on file, have worked with US federal sponsors before, have staff familiar with processing and managing awards.  “High-risk” subrecipients may be far away geographically (so potentially difficult to monitor for compliance or difficult to communicate with), be located in parts of the world where financial fraud is common, have staff unfamiliar with sponsored programs administration, lack adequate internal controls, lack infrastructure to support research projects, or be otherwise unable or unwilling to comply with grant requirements.

“Moderate risk” would have come combination of these pluses and minuses.

Some of these can be mitigated with agreements in advance.  For example, if the subrecipient organization has no financial conflict of interest policy, they may be willing to abide by yours during the project.

My suggestions would be to establish up front the systems you will use to monitor the work and the finances.  Provide monthly statements of project funds spent versus funds remaining and have them sign and verify those statements periodically.  Ask for invoices with receipts (amounts converted into US dollars if necessary).  If there is a cash advance involved, make the terms and conditions of that advance clear.  Make sure they understand reasonable/allocable/necessary expenditures and any specific award restrictions.

It is better to have these conversations during the proposal writing process if possible.

Hope this helps.

Ann Marie Hoffman, M.S.
Research Administrator
CNS Office of Research Support
Michigan State University
288 Farm Lane Room 103
East Lansing, MI 48824-1115
Phone: (517) 432-7165
xxxxxx@msu.edu<mailto:xxxxxx@msu.edu>

From: Research Administration List <xxxxxx@LISTS.HEALTHRESEARCH.ORG> On Behalf Of Megan Roth
Sent: Friday, October 18, 2019 12:18 PM
To: xxxxxx@LISTS.HEALTHRESEARCH.ORG
Subject: [RESADM-L] High Risk Subawards

As I explore some "tricky" potential subawards in the future, I am wondering the following:

What kind of matrix do you use to determine the level of risk of a subrecipient? i.e., what defines low, moderate, high risk?

What does "extra monitoring" of a high risk subrecipient look like to you? What practices should be put in place to determine that we have an adequate level of monitoring?

Thanks in advance!!

--
Megan Roth, Ph.D.
Executive Director of Research
Abilene Christian University
320 Hardin Administration Bldg
ACU Box 29103
Abilene, TX 79699
O: 325-674-2885
F: 325-674-6785
xxxxxx@acu.edu<mailto:xxxxxx@acu.edu>

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