Subrecipient Monitoring
The University is responsible for monitoring the programmatic and financial activities of its subrecipients to ensure proper stewardship of sponsor funds.
Reason for Monitoring
OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) ("Uniform Guidance"), specifically 200.331, requires pass-through entities to evaluate each subrecipient's risk of noncompliance in order to determine the appropriate monitoring level, monitor the activities of subrecipient organizations to ensure that the subaward is in compliance with applicable Federal statutes and regulations and terms of the subaward, and verify that subrecipients are audited as required by Subpart F of the Uniform Guidance.
Who Must Comply
All PI's and department administrators involved with the administration and conduct of sponsored projects that issue and manage subawards must comply.
Roles and Responsibilities
PI's and departments have primary responsibility for the following:
- Assess potential subrecipient organizations for programmatic, financial, and administrative suitability at the time of proposal
- Request subrecipient organization information or request expedited review of subrecipient organization at the proposal stage, if necessary
- Confirm the statement of work (SOW) and review any non-standard terms and conditions of the subaward during the subaward agreement negotiation process
- Monitor programmatic progress and ability of the subrecipient to meet objectives of the subaward
- Monitor each subaward through the period of performance and escalates concerns to OSP
- Monitor subrecipients to ensure compliance with federal regulations and both prime and subrecipient award terms and conditions.
- Obtain copies of the Single Audit Reports if the entity is subject to Uniform Guidance, or request financial or other relevant information for institutions not subject to single audit requirements.
PI's are responsible for evaluating the quality of the work performed by subrecipients and ensuring that contractual agreements are met. Department administrators have responsibility for assisting PIs in discharging their monitoring responsibilities, for reviewing invoices from subrecipients and questioning expenditures if necessary, and for maintaining documentation of monitoring efforts.
OSP will:
- Review information obtained for initial subrecipient organization risk assessment and assign a risk rating
- Incorporate additional terms into subawards based on information from the PI, department, and the risk assessment of the subrecipient
