Subrecipient risk analysis tool

The subrecipient risk analysis category guidelines and examples help investigators understand how subrecipient risk is evaluated during the proposal development process. Review the risk categories, assessment criteria, and example scenarios used to support consistent risk determinations and ensure compliance with sponsor and university requirements.

Category	Score = 0 (lower risk)	Score = 1 (higher risk)
Foreign vs domestic	Domestic (US only)	All other foreign entities
Maturity of subrecipient's organization	Mature	Start-up, no fiscal controls in place yet
Organization type	University or non-profit (Collegial T&Cs)	Industry organization
Award type	Grant from federal or non-commercial source	Contracts (includes subcontracts, CTAAs)
Subgrant/subcontract	Total cost is <$199,000	Total cost is > $200K
Percentage of award contracted	Total cost is < 49%	Total cost is > 49%
Procurement systems	Systems have been approved (existing A-133 is an indicator)	No systems are in place, or systems are new
Accounting systems	Yes	No
Negotiated Indirect Cost Rate Agreement	Has detailed negotiated rate agreement	Does not have negotiated rate agreement
Audit report	Has annual A-133 audit	Has not had an annual financial audit
Prior experience	Previous positive experience as NAU subrecipient	New subrecipient or previous negative experience as NAU subrecipient
ITAR/EAR	No export controlled activity involved	Organization or project involves ITAR (e.g. satellites, biological warfare)
Compliance (animal/human subjects, DNA, stem cells)	No compliance issues involved, or exempt per IRB	A/S, H/S, or other compliance issues involved, higher risk activities
Location of work	At subrecipient's facility	On NAU campus
Sponsor type	Non-federal organizations or routine federal award programs (NSF, NIH)	Government-owned/contractor Operated (e.g. national labs)
Relationship of subrecipient PI	No relationship except collaborative/research-based	Conflict of Interest involved (e.g. family relations, PI is on board or hold stock in organization)
Scope of work and deliverables	Report only	Tangible products, deliverables necessary in order to achieve project success
Advantaged status	No claimed status (small business, HUB zone, women/minority-owned, etc.)	Two or more claims
Special considerations	Additional information which raises risk level, e.g. high funding level, risk category requiring a higher level of scrutiny	Additional information which raises risk level, e.g. high funding level, risk category requiring a higher level of scrutiny

NOTE: If cost share for sub, then higher risk rate.

Risk categories are analyzed on a sliding scale, so risk levels are based on the Office of Sponsored Projects (OSP) Administrator’s evaluation. If the OSP has concerns with the subrecipient, the risk analysis score can be bumped up to the next level.