Subrecipient Monitoring Policy

Policy number17-04.11
Responsible officeResearch
Enforcement officialVice President for Research
Category17. Research and Intellectual Property

Statement of policy

The Universitywill comply with the Office of Management and Budget (OMB) Uniform Guidance regarding the University’s monitoring and stewardship obligations as the primary award recipient when accepting sponsored funding and assigning responsibility for conducting a portion of the work to another entity through a subaward agreement.  

Summary of contents/major changes

Moved to Policy Template 

1. Purpose of Policy 

As the prime recipient of an award, which includes one or more outgoing subawards to other entities, the University has the responsibility for ensuring that all research under the prime award is conducted and administered in compliance with sponsor requirements and University 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 a subrecipient organization.

2. Stakeholders Most Impacted by the Policy 

This policy applies to federally funded subawards issued under federally sponsored awards made to Western Michigan University (WMU). The corresponding procedures are intended for use by Principal Investigators, Department Administrators and the Office of Research and Innovation to define their respective roles and responsibilities for subrecipient monitoring. This Policy does not apply to consulting agreements or other forms of vendor procurement.

3. Key Definitions 

3.1 Pass-through entity Uniform Guidance §200.74

  • Pass-through entity means a non-Federal entity that provides a subaward to a subrecipient to carry our part of a Federal Program. 

3.2 Subrecipient Uniform Guidance §200.93

  • Subrecipient means a non‐Federal entity that receives a subaward from a pass‐through entity to carry out part of a Federal program; but does not include an individual who is a beneficiary of such program.  A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency.

3.3 Subaward Uniform Guidance §200.92

  • Subaward means an award provided by a pass‐through entity to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass‐through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass‐through entity considers a contract.

3.4 Subrecipient Monitoring 

  • 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 a subrecipient organization.
    Note: For the purposes of this policy, where reference is made to "research" awards, it is defined as all awards (i.e., training grants, etc.) where a subaward is issued. Similarly, where reference is made to "subaward," it may refer to a subrecipient agreement, subcontract, or consortium agreement, dependent upon the nature of the prime award.

3.5 Contractor 

  • A contractor is defined as "an entity that receives a contract,” which is defined as “a legal instrument by which a non‐Federal entity purchases property or services needed to carry out the project or program under a Federal award. The term as used in this part does not include a legal instrument, even if the non‐Federal entity considers it a contract, when the substance of the transaction meets the definition of a Federal award or subaward.”

3.6 Substantive work conducted by a third party 

  • Project activities that are of primary purpose to the research program  but are not conducted at the University. These activities constitute a significant portion of the research program and require the leadership and direction of a responsible investigator located at the work site of the cooperating entity.

4. Full Policy DETAILS 

It is the policy of Western Michigan University 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 prime award. As the prime sponsored award recipient (the Pass‐through entity), the University is responsible for ensuring that 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 satisfies institutional and governmental reviews as well as governmental audits while providing adequate stewardship of the research enterprise at WMU.

5. Accountability 

5.1 Failure to adhere to these Federal regulations in connection with a specific subrecipient monitoring may result in the withholding of new awards.

5.2 Additional consequences for non-compliance include possible individual discipline for failure to follow applicable University policies and requirements.

6. Related Procedures and Guidelines 

Subrecipient Administration and Monitoring Procedures 


Effective date of current versionDecember 1, 2019
Date first adoptedDecember 1, 2014
Proposed date of next reviewAugust 1, 2022


Certified by

Betty McKain

Director of Grants and Contracts 

At the direction of

Terri Goss Kinzy

Vice President for Research and Innovation