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Risk Assessment
What is a subrecipient risk assessment?
A risk assessment is a way to evaluate the potential financial and compliance risk of a subrecipient or subawardee on a project. Several factors are considered when determining the level of risk associated with a subrecipient.
The Federal Uniform Guidance (2 CFR 200.332c) requires IU to “evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring."
To comply with this requirement, IU's Office for Research Administration performs a risk assessment on federal and federal pass-through projects with a cost reimbursable subaward or subaward amendment with additional funding.
High-risk subrecipients require additional monitoring
According to Federal Uniform Guidance (2 CFR 200.332e), IU must "monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved."
When IU determines that a subrecipient should be considered high–risk, the subaward agreement will include additional terms and conditions, including specific invoicing instructions and a Subrecipient Invoice Template (Accessible 03/12/24). An example of the additional invoicing instructions can be found in the High-Risk Billing Requirements Attachment (Accessible 06/03/21).
Departments will perform a complete review of the invoice and required supporting documentation prior to invoice approval. If any information is missing, incorrect, or appears to be unallowable, the fiscal officer must hold or cancel the payment request and contact the subrecipient for resolution.
High risk = audit risk
Subrecipient monitoring reduces the risk of doing business with an external entity. It is highly recommended that departments use the High-Risk Subrecipient Invoice Checklist to document their subrecipient invoice review and approval. As part of Indiana University’s annual Single Audit, auditors will test the university’s compliance with federal laws that require monitoring subrecipients.