Responsibility: KE Contracting Services and Fiscal Operations
Prepared by: Subawards Functional Group and Fiscal Operations Team (FOT)
Work Instruction Number: WI-MS-70
Updated: January 24, 2025
Monitoring for 2 CFR 200 (Uniform Guidance) audit compliance
Monitoring for 2 CFR 200 (uniform guidance) audit compliance
For all subawards, Arizona State University requires the sub-recipient to make an annual disclosure of any sponsored research audit findings. This annual disclosure is required prior to issuance of a subaward or modification. The Fiscal Oversight Team (FOT) monitor for this compliance. The detailed instructions titled “Assessing Subrecipient Risk Job Aid” are located in Post Award’s internal SharePoint training folder.
Monitoring for FFATA
In accordance with the Federal Funding Accountability and Transparency Act (FFATA), Arizona State University is required to provide the Federal government with monthly information regarding all ASU issued subawards through the FSRS Website. The following steps are completed by the Subawards GCO to determine whether FFATA Reporting is required:
Step 1: Federal Funding is involved
Step 2: ASU is the Prime Recipient and ASU is issuing a subaward
Step 3: This is a new Prime Award – or – a Transfer Award with a new FAIN that meets the Obligated Funding and Award Date Requirements included in Step 4 below.
Step 4: Review the Prime Award and determine if any of the following are true.
Grants and Cooperative Agreements:
- Prime award is greater than or equal to $25,000 [Awarded 10/1/2010 and after]
Contracts:
- Prime award is greater than or equal to $30,000 [Awarded 10/1/2015 and after]
- Prime award is greater than or equal to $25,000 [Awarded 3/1/2011 – 9/30/2015]
- Prime award is greater than or equal to $550,000 [Awarded 10/1/2010 – 2/28/2011]
- Prime award is greater than or equal to $20,000,000 [Awarded prior to 10/10/2010]
Step 5: Review the subaward and determine if any of the following are true.
- This is a new subaward greater than or equal to $25,000 [Awarded prior to 11/12/2020] or $30,000 [Awarded 11/12/2020 and after] which ASU has not yet reported in FFATA Subaward Reporting System (FSRS) – or –
- This is a subaward modification that will increase the total subaward amount from less than $30,000 to $30,000 or more and ASU has not yet reported in FFATA/FSRS – or –
- ASU already reported this subaward in FFATA/FSRS and this modification will increase/decrease the prior obligated funding
The subaward does not need to be reported if the following situations occur:
- Direct Sponsor is non-federal*
- Prime award involves ARRA Funding
*Note: The non-federal direct sponsor would need to report Arizona State University in FSRS as a subaward, but second tier subawards (i.e., the subawards ASU would issue under this type of award) are not required to be reported in FSRS.
For details on the process, see FFATA Reporting Process for ASU Issued Subawards.