Purple Sheep CPE™

MODULE TITLE

Purple Sheep CPE™ — Institutional Funding & Proposal Development (Pre-Award) Module 4: Subrecipient Governance & Third-Party Accountability

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PROGRAM IDENTIFICATION

Purple Sheep CPE™
Institutional Funding & Proposal Development (Pre-Award) Series™
1.0 CPE Contact Hour | Self-Paced Professional Education

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MODULE OVERVIEW

Subrecipient relationships extend institutional responsibility beyond internal operations. They do not transfer accountability.

Institutions remain responsible for ensuring that third-party collaborators operate in alignment with regulatory requirements, sponsor expectations, and institutional control systems. Weak subrecipient governance introduces external risk that is often difficult to detect, monitor, and correct.

This module provides a structured, risk-based examination of how institutions govern subrecipient relationships and enforce third-party accountability. It focuses on monitoring systems, documentation expectations, financial oversight, and escalation mechanisms required to maintain institutional compliance.

Institutional exposure rises when subrecipient oversight is inconsistent, documentation is incomplete, or accountability is assumed rather than enforced. These weaknesses create recurring risk because third-party activity often operates outside direct institutional control while still remaining fully attributable to the institution.

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KEY AREAS OF FOCUS

This module examines:

• Subrecipient governance frameworks within institutional environments
• Institutional responsibilities in third-party collaborations
• Monitoring systems and documentation expectations for subrecipients
• Financial oversight of subrecipient activity
• Escalation, accountability, and corrective action readiness

These areas represent critical external control points where institutional risk is introduced and must be actively managed.

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PROGRAM STRUCTURE & INSTRUCTIONAL DESIGN

This module is structured to reinforce institutional oversight beyond internal boundaries.

The module includes:

• Scenario-based analysis reflecting real subrecipient risk conditions
• Structured evaluation of monitoring gaps and third-party accountability failures
• Applied learning activities designed to assess governance strength and response readiness
• Knowledge validation through formal assessment

Topic structure follows the standardized Purple Sheep CPE™ model, including required engagement activities and a formal knowledge check to support audit defensibility.

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REGULATORY & COMPLIANCE ALIGNMENT

This module aligns with established regulatory and internal control frameworks, including:

• 2 CFR 200 (Uniform Guidance)
• ICH Good Clinical Practice (E6)
• Applicable FDA regulations governing sponsored and clinical activity
• COSO Internal Control Framework principles

Content reflects how subrecipient monitoring and accountability requirements are operationalized within institutional environments.

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LEARNING OBJECTIVES

Upon completion of this module, participants will be able to:

• Evaluate institutional exposure introduced through subrecipient relationships
• Assess whether third-party accountability structures are clearly defined and enforceable
• Analyze monitoring systems for completeness, consistency, and effectiveness
• Identify documentation gaps that weaken subrecipient oversight
• Determine when escalation and corrective action are required
• Apply governance-based approaches to strengthening third-party accountability

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COMPLETION & AUDIT VERIFICATION

Completion of this module requires:

• Full review of all instructional content
• Completion of required engagement activities
• Successful completion of the knowledge check assessment

Participant progression and completion data are recorded to support institutional documentation and audit verification requirements.

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SERIES CONTINUITY

This module extends institutional control systems beyond internal operations into third-party environments.

It supports subsequent modules addressing:

• Documentation systems and financial compliance controls
• Award closeout governance and institutional exposure

The strength of subrecipient governance directly influences institutional audit outcomes, financial integrity, and regulatory compliance across collaborative research activity.

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CPE STATEMENT

This module, combined with required engagement activities, represents 1.0 CPE contact hour.

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CREDENTIAL ALIGNMENT

This module is designed to support continuing education and professional development aligned with:

• Research Administrators Certification Council (RACC) expectations (CRA, CPRA, CFRA)
• Clinical research compliance and certification domains, including the Certified Clinical Research Professional (CCRP) credential administered by the Society of Clinical Research Associates (SOCRA)
• Clinical research competencies aligned with ACRP certification frameworks
• Internal audit and compliance competencies aligned with CIA principles

Module Access & Availability

Access to individual modules is provided for 90 days from the date of enrollment.

Individual modules are offered as part of the initial launch phase through December 31, 2026. Beginning January 2027, Purple Sheep CPE™ will transition to a series-based model designed to support deeper learning, stronger outcomes, and institutional alignment.