Compliance Management Services
Our team monitors the University's adherence to numerous federal, state, local, and administrative laws and regulations. This is to ensure adequate policies, procedures, and guidance area available to promote to achieve compliance.
Uniform Guidance (2 CFR Part 200) is a government-wide framework for grants management that provides an authoritative set of rules and requirements for federal awards. This guidance serves as the foundation used to develop policies for grants and agreements.
In accordance with federal regulation (34 CFR 200.302), effective internal controls, and accountability, over federal awards must be established and maintained to provide reasonable assurance that the award is being managed in compliance with regulations. In addition, prompt action must be taken when instances of noncompliance are identified. To promote compliance, consistency, and uniform understanding, effective internal controls are required for all activity, regardless of funding source.
A subaward occurs when a portion of the University’s sponsored project is passed through to another entity (the subrecipient) to complete a portion of the sponsored project’s scope of work. The terms and conditions of the University’s award flow down to the subrecipient as part of the subaward. Therefore, subrecipients must adhere to applicable federal compliance requirements contained in the prime award.
In accordance with federal regulation (2 CFR 200.332), all pass-through entities must perform subrecipient monitoring to ensure the subaward is being used for the authorized purpose, in compliance with the federal requirements and terms and conditions of the subaward. The responsibility for subrecipient monitoring is a team effort that requires the coordination of multiple parties. For example, the Office of Sponsored Awards Management reviews and approves subaward contracts, while the Principal Investigator monitors the scope of work and project progress.
The monitoring performed by the Office of the Controller includes reviewing annual audit certification surveys and assigning respective risk ratings to subrecipients, completing desk reviews of subrecipient invoices, and performing ongoing compliance reviews of invoices submitted for processing. Per 2 CFR 200.305, pass-through entities have 30 days to make payment after receipt of the proper invoice, unless it is reasonably believed to represent an improper request.
To ensure proper processing, timely review, and compliance with the terms and conditions of the respective subaward agreements, subrecipients must submit invoices directly to the Office of the Controller through the Subaward Invoice Payment Request Form.
Effective 11/1/2023, this submission method was implemented to improve the subrecipient invoice process. Only those invoice submissions associated with a subaward agreement should use this form above. Submissions unrelated to subawards will not be reviewed or submitted for payment. See the Subrecipient Monitoring and Training webinar for additional information.
- Subaward Invoice Payment Request Form
- Policy FINA 3.31 – Subrecipient Monitoring [pdf]
- Procedure FINA 3.31 – Subrecipient Monitoring [pdf]
- FINA 3.31 Appendix – Risk Classification Matrix [pdf]
- Subaward Agreement Process [pdf]
- Subrecipient Commitment Form [pdf]
- Sample Invoice [pdf]
- Closure of Subaward Purchase Orders [pdf]
In accordance with federal regulation (34 CFR 86.100) and the Federal Student Aid Handbook (Volume 2, Chapter 6), institutions of higher education that participate in Federal Student Aid programs must have a drug and alcohol prevention program and provide its students, faculty, and employees with information to prevent drug and alcohol abuse. The Office of the Controller will monitor compliance with these requirements. For related inquires and assistance, contact controllercompliance@sc.edu.
In accordance with federal regulation (20 U.S. Code Section 1011f), any institution that receives a gift from or enters into a contract with a foreign source, the value of which is $250,000 or more on an individual or aggregate basis, must file a disclosure report semiannually with the U.S. Department of Education. The Office of the Controller will collect gift and contract data from applicable parties and file the required reports accordingly. For related inquires and assistance, contact controllercompliance@sc.edu.
- FINA 1.50 [pdf] - Foreign Gift and Contract Section 117 Reporting
- FINA 1.50 Procedure [pdf] - Foreign Gift and Contract Reporting
- FINA 1.50 Template [xlsx] - Foreign Gift and Contract Reporting
In accordance with federal regulation (2 CFR 200.430), charges to federal awards for salaries and wages must be reasonable in relation to the work performed, ensuring the time charged to sponsored awards is commensurate with the actual effort expended on all activities performed. To fulfill this requirement, employees, along with respective Principal Investigators (PI) and supervisors, must complete semiannual certification of time and effort. The effort reports are made available through HCM PeopleSoft and summarize the proportion of work time devoted to sponsored awards and other activities, expressed as a percentage of total effort, using the employee’s Institutional Base Salary.
The Office of the Controller will monitor the completion of effort reports, completing follow-up as necessary. Failure to certify effort reports in a timely manner could result in the removal of charges from sponsored projects to departmental accounts. Semiannual time and effort reporting represents an after-the-fact certification and should not serve as the only mechanism for monitoring salaries at the departmental level. Payroll charges must be monitored on a regular basis, with any necessary adjustments processed in a timely manner. For related inquires and assistance, contact gfmecert@mailbox.sc.edu.
Visit the Business Manager, Grant Administration, and Principal Investigator training resource pages for additional Time and Effort Reporting resources.