Procedure Library

Monitor an Active Subaward

Purpose

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.

Applicability

Principal Investigators (PIs) whose sponsored project includes a subaward to another organization (the subrecipient). PIs and departments have primary responsibility for properly monitoring subrecipients to ensure compliance with federal regulations and both prime and subrecipient award terms and conditions.

Roles of the Principal Investigator and the Department

Upon audit or request, the University and PI must provide documentation that monitoring has occurred, including documenting correspondence and receipt of progress reports.

Upon execution of a new subaward, OSP will email the PI and department a link to this procedure along with additional information.

Template: Subrecipient Monitoring Record (doc)
This checklist serves as a tool to help with subrecipient monitoring compliance.

1. Identifying the Potential Subrecipient
   The PI is responsible for the due diligence involved with selecting a potential subrecipient. In the case of sub-contracts on prime government contracts, the PI documents their selection from a competitive bidding process, or a single or sole source written justification. In all cases the PI must assure that the proposed subrecipient is technically qualified. The scope of work and the overall budget amount are determined by the PI. Additionally, the PI is responsible for gathering all required documentation prior to submission.
   
   1. Determining Subrecipient or Contractor Status
      The PI is responsible for properly determining on a case-by-case basis whether an entity receiving an agreement has the role of contractor or subrecipient. See Determine Subrecipient or Vendor Procedure.
   2. Foreign Subrecipients
      The PI is responsible for obtaining a letter of intent (LOI and W-8 from all foreign subrecipients and attaching in eProposal. See Foreign Subawards - Data Access Procedure.
2. Communication with the Subrecipient
   Information contained in the subaward states the deliverables required, administrative requirements and applicable laws and regulations with which the subrecipient must comply. This agreement and the referenced prime award define the subrecipient relationship. The PI and any designees administering the subaward should be familiar with the terms and conditions of the agreement.
   1. Communication should continue throughout the collaboration through telephone calls, emails, letters and site visits, as necessary.  icon Any potential conflict or issues regarding non-compliance should be immediately brought to the attention of OSP.
3. Work with OSP to Modify the Subaward
   Any changes or modifications to the subrecipient agreement shall be approved and executed through OSP. This includes all PI/departmental and subrecipient requests for re-budgeting, foreign travel, equipment purchases, subrecipient PI changes and the hiring of consultants.
4. Review and Monitor Subrecipient's Technical Performance and Progress
   1. Verify that the subrecipient's statement of work is performed timely and is in line with the proposed and funded statement of work (SOW).
   2. Review the technical/performance reports.
   3. Verify that the subrecipient's compliance requirements are up-to-date (e.g. approvals for human subjects or animal subjects).
   4. Maintain regular contact with the subrecipient.
   5. Communicate any deficiencies to the subrecipient in a timely manner.
5. Foreign Subrecipients and Data Access Requirements
   Foreign subrecipients are required to provide copies of all lab notebooks, all data, and all documentations that supports research outcomes as described in the progress report. The PI is reponsible for ensuring that these supporting materials are provided at an agreed upon frequency (no less than once a year) and in line with the reporting timelines outlined in the agreement. See Foreign Subawards - Data Access. 
6. Invoice and Payment Processing
   When approving invoice payments to subrecipients on cost reimbursable awards, the validity of expenses must be verified along with achievement of scientific and technical progress by the PI or department designee. 
   
   NOTE: As a result of findings from a subrecipient monitoring audit, PI's (or approved alternates), are now required to approve all subaward invoices submitted for payment regardless of amount. Previously, PI approval was only required for invoices over $50,000. As of August 1, 2018, UShop will route for approval all subaward invoices to the PI of the award and approved alternates. 
   1. Ensure than invoices are received on schedule. Communicate with the subrecipient to urge timely submission of invoices.
   2. Ensure that charges to the project are allowable, allocable, reasonable, and within the period of performance.
   3. Ensure that the percent effort charged to the project is in line with the effort proposed in the approved (funded) budget.
   4. Notify OSP and Accounts Payable if payment will be temporarily withheld due to unallowable expenses or other significant reasons (2 CFR 200.305(6)), document the issue and resolve with the subrecipient. 
   5. Approve final invoices in a timely manner for closeout.
7. Program Income and Cost Sharing
   The PI shall verify that the subrecipient included receipt of program income and cost sharing obligations on invoices submitted to the University.
8. Subrecipient Award Closeout
   The subrecipient award closeout process shall begin promptly upon the conclusion of the period of performance. Final invoices must be submitted to the University in accordance with the time period specified in the agreement. Failure by the subrecipient to submit any deliverables by its due date shall be considered just cause for the University to withhold payments. 
   
   Deliverables include audit and performance reports, technical reports, financial reports, final invoices, and Contractor's Release forms if applicable. Final payments to subrecipients shall not be approved until all closeout documents and deliverables have been received. 
9. Record Retention

   1. Documentation concerning monitoring activities and results will be maintained by the PI in accordance with University Rule 3-014A: Financial Records Retention and Disposal

Related Policies and Procedures

• Research Handbook > Award Management > Role of PI in Subrecipient Monitoring
• Grant Life Cycle > Develop Your Proposal > Obtain Subrecipient Documentation
• Grant Life Cycle > Manage Your Award > Subrecipient Closeout