Procedure Library

Monitor an Active Subaward

Purpose

Monitor a subrecipient's progress and performance on a sponsored project.

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.

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 Subrecipient Monitoring Record (doc), along with additional documentation. This checklist serves as a tool to help with compliance of this requirement.

Instructions

1. OSP issues a subaward that includes required terms and conditions and required data elements so that the subrecipient has information needed to comply with federal regulations and sponsor award terms.
2. 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.
3. Review and approve subrecipient invoices. NOTE:As a result of findings from a subrecipient monitoring audit, PI's (or approved alternates), will now be 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.
4. Work with OSP to make any needed changes to the subaward.
5. Work with OSP to close out the subaward after all reports and other deliverables have been received and the final invoice has been paid.

Related Policies and Procedures

• Grant Life Cycle > Develop Your Proposal > Obtain Subrecipient Documentation
• Grant Life Cycle > Manage Your Award > Subrecipient Monitoring
• Grant Life Cycle > Manage Your Award > Subrecipient Closeout