Risk Assessment Implications: Imposition of Specific Terms and Conditions

Additional or specific Terms and Conditions will be set forth on a case-by-case basis, addressing specifically any elevated risk identified by the SRA.  These may include the following requirements:

• Additional project monitoring requiring monthly or quarterly progress reports.  This will ensure that the project is on track (in-line with the SOW) and will allow for any issues related to the project to be addressed.
• The PI may schedule site visit(s) to the subrecipient’s location.
• More frequent and/or more detailed financial reports.
• Submission of detailed invoices, including supporting/backup documentation.
• Periodic desk audit(s) to ensure that subaward expenditures are allowable and in-line with the SOW and budget.
• Imposition of specific Terms and Conditions addressing audit finding(s).

Completed SRAs resulting in a Moderate or High Risk level will be reviewed by the Director of Research Services.  Final determination and imposition of specific Terms and Conditions is determined by Research Services and the Vice Provost for Research (VPR) in consultation with the PI.

Final risk assessments, required Management Decisions (if applicable, as required for adverse audit findings), and determination of specific, additional Terms and Conditions must be shared with all parties that have subrecipient monitoring responsibilities, including the subrecipient’s PI and contact person, the PTE’s PI and departmental contact, Research Services and the VPR.  The notification shall indicate the nature of the additional terms and conditions, the rationale for the additional terms and conditions, the action(s) necessary for removal of the additional terms and conditions, the time allowed for completing the required actions, and the methods for requesting reconsideration of the additional terms and conditions.  The additional Terms and Conditions shall be removed once the deficiencies have been corrected.

Last updated: 4/27/2021