Category Risk Medium Risk Higher Risk 1. Foreign vs. Domestic (US only) Canada, US territories All other international Domestic locations 2. Facilities and Work occurs in adequate, Some work done at UMMS Subrecipient's lab Infrastructure established space at facilities resources are subrecipient’s facility inadequate, requiring that work occur on UMMS campus 3. Maturity of Mature (e.g. more than Mature, but not research Start-up, no fiscal Organization 10 years) oriented controls in place yet 4. Organization University or Non-profit University or Non-profit with Industry organization Type (Collegial Terms and more restrictive T&Cs (e.g. state Conditions (T&Cs) regulations) 5. Award Type Grant from federal or Coop agreement or grant with Contracts and contracts non-commercial source special conditions with subcontracts 6. Amount/ Lower funding levels or Funding is a large part of smaller Funding level>$500K or Percentage of percentage of total funds award >49% of award Award allocated to subrecipient Subcontracted (e.g. <$100k) 7. Accounting/ Systems have been Systems less qualified to handle No systems are in place, Procurement approved (existing audit large amounts of federal money or systems are new Systems is an indicator) (Financial audit conducted but not required by Uniform Guidance Audit Requirements) 8. Negotiated Has detailed negotiated Has simple rate agreement Does not have Indirect Cost rate agreement negotiated rate Rate Agreement agreement 9. Audit Report Has annual audit as Has annual third-party financial Has not had an annual required by Uniform audit financial audit Guidance Subpart F 10. Prior experience Previous positive Previous experience as UMMS New subrecipient or with UMass experience as UMMS subrecipient but may have some previous negative Medical School subrecipient minor concerns experience with subrecipient. 11. ITAR/EAR No export controlled Collaborative agreements with Organization or project activity involved potential for ITAR control needed involves ITAR (e.g. satellites, biological warfare) 12. Compliance No compliance issues Animal Subjects or Human Animal/human subject (animal/human involved, or exempt per Subjects involved, but or other compliance subjects, DNA, IRB or non-invasive issues involved, higher stem cells) risk activities Subrecipient PI is a No previous 13. Scientific Relationship familiar collaborator collaboration between UMMS PI and Subrecipient PI
Category Risk Medium Risk Higher Risk 1. Foreign vs. Domestic Domestic (US only) Canada, US territories All other international locations 2. Facilities and Infrastructure Work occurs in adequate, established space at subrecipient’s facility Some work done at UMMS facilities Subrecipient's lab resources are inadequate, requiring that work occur on UMMS campus 3. Maturity of Organization Mature (e.g. more than 10 years) Mature, but not research oriented Start-up, no fiscal controls in place yet 4. Organization Type University or Non-profit (Collegial Terms and Conditions (T&Cs) University or Non-profit with more restrictive T&Cs (e.g. state regulations) Industry organization 5. Award Type Grant from federal or non-commercial source Coop agreement or grant with special conditions Contracts and contracts with subcontracts 6. Amount/ Percentage of Award Subcontracted Lower funding levels or percentage of total funds allocated to subrecipient (e.g. <$100k) Funding is a large part of smaller award Funding level>$500K or >49% of award 7. Accounting/ Procurement Systems Systems have been approved (existing audit is an indicator) Systems less qualified to handle large amounts of federal money (Financial audit conducted but not required by Uniform Guidance Audit Requirements) No systems are in place, or systems are new 8. Negotiated Indirect Cost Rate Agreement Has detailed negotiated rate agreement Has simple rate agreement Does not have negotiated rate agreement 9. Audit Report Has annual audit as required by Uniform Guidance Subpart F Has annual third-party financial audit Has not had an annual financial audit 10. Prior experience with UMass Medical School Previous positive experience as UMMS subrecipient Previous experience as UMMS subrecipient but may have some minor concerns New subrecipient or previous negative experience with subrecipient. 11. ITAR/EAR No export controlled activity involved Collaborative agreements with potential for ITAR control needed Organization or project involves ITAR (e.g. satellites, biological warfare) 12. Compliance (animal/human subjects, DNA, stem cells) No compliance issues involved, or exempt per IRB Animal Subjects or Human Subjects involved, but or non-invasive Animal/human subject or other compliance issues involved, higher risk activities 13. Scientific Relationship between UMMS PI and Subrecipient PI Subrecipient PI is a familiar collaborator No previous collaboration
umms-subrecipient-risk-assessment-matrix.docx