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Foreign Subrecipients and Small Community-Based Partners Guidance

This guidance document is an attempt to help explain some of the documents and compliance requirements that may not be clear to our foreign and small community based subrecipients. As the recipient of prime funding, UNC is responsible opens in a new tab for ensuring all requirements of the prime sponsor are followed by our subrecipients.

Audit Questionnaire

All non-federal entities who expend more than $750,000 of federal funds in a year are subject to an annual audit in accordance with Uniform Guidance, also called a Single Audit opens in a new tab. If the subrecipient is not subject to a Single audit, UNC uses an annual audit questionnaire to meet our subrecipient monitoring requirements. The questionnaire helps UNC’s Audit and Compliance team determine the status of the subrecipient’s compliance with Federal requirements regarding use of Federal funds as well as determines a subrecipient’s risk level and whether additional subrecipient monitoring needs to be put into place to ensure compliance. This questionnaire is entity specific and not project specific.

COI Training/Disclosure (for projects funded by PHS agencies or NSF)

As the prime recipient of funds from a Public Health Service (PHS) agency opens in a new tab or National Science Foundation (NSF), it is the responsibility of UNC to ensure each subrecipient has a Conflict of Interest policy compliant with the PHS/ NSF requirements opens in a new tab.

  • UNC uses the FDP Clearinghouse opens in a new tab as the first of many potential ways to verify if a subrecipient’s Conflict of Interest (COI) policy is compliant. UNC OSP maintains a database of subrecipient compliance information including whether a subrecipient has a COI policy in compliance with PHS/ NSF requirements.
    • If it is determined the subrecipient does not have a COI policy in compliance with PHS/ NSF requirements and the project is funded by a PHS agency or NSF, the subrecipient must rely on UNC’s COI policy opens in a new tab.
  • UNC must maintain a record of all individuals that are subject to UNC’s COI policy, including subrecipient personnel, ensuring that COI training is maintained during the project and any disclosures are completed as required.
  • During the proposal stage, the Letter of Intent is used to obtain the status of COI for the subrecipient.
    • If a subrecipient self discloses they do not have a compliant policy, they will include the personnel names, roles, and email addresses directly on the LOI. This often expedites the COI process as the personnel are added to the system by UNC’s department at proposal stage and subrecipient personnel can complete COI training and disclosures prior to award execution.
    • If a subrecipient certifies they do have a compliant policy, UNC must confirm.
      • If it is determined that the subrecipient’s policy is not compliant, the Subrecipient Personnel Change – Conflict of Interest form (PDF) is needed. Once this is received, UNC OSP will add personnel to the system to generate training and disclosure links (as applicable). Subrecipient personnel will receive email(s) to complete the required steps. Until the COI is clear, UNC is unable to fully execute the subagreement.
    • If personnel that were previously provided, either on the LOI or a prior year COI form, have changed, the Subrecipient Personnel Change – Conflict of Interest form (PDF) will need to be used to make any needed updates to the subrecipient’s personnel subject to UNC’S COI. This form can be sent to OSPSubs@unc.edu or via SPARC when certifying a current action.
    • COI training certification is valid for 4 years; thereafter a COI Refresher Training opens in a new tab is available. COI disclosures for applicable personnal are project specific.

Attachment 3B

Attachment 3B provides contacts related to the subrecipient to ensure communication is routed to the appropriate individual with the subrecipient. Page 2 of Attachment 3B is required to be completed unless the subrecipient is exempt from reporting executive compensation under 48 CFR § 52.204-10 opens in a new tab and have indicated such on the Attachment.

Determine whether cash flow is an issue for the foreign or small community-based subrecipient and whether advanced operating capital may be needed for them to perform their scope of work. If so, be sure to indicate the need for a cash advance and a justification for advance requests greater than 25.1% on the SPARC certification.

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