Responsibility: ORSPA-PNT and ORSPA-FOT
Prepared by: PNT
Work Instruction Number: WI-MS-70
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. Details on Fiscal Oversight Team (FOT) monitoring for this compliance are located in Assessing Subrecipient Risk Job Aid.
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. For ASU to process a subaward, the following steps are followed 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
Step 4:
- Grants and Cooperative Agreements
- The Prime Award is greater than or equal to $30,000 [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 and after]
- 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:
- This is a new subaward greater than or equal to $30,000 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
For details on the process, see FFATA Reporting Process for ASU Issued Subawards.