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Business and Financial Policies and Procedures

Responsibilities to Monitor a Subrecipient

The Principal investigator (PI), the unit business manager, and the university Grants and Contracts office (GCO) share the responsibility of monitoring subrecipients.

The Principal Investigator and Unit Business Manager:

  • Verify that work performed by the subrecipient is conducted in a timely manner and is acceptable.
  • Review and compare subrecipient invoices to established budgets to ensure cost are allowable.
  • Certify/approve all subrecipient invoices and submit for payment.
  • Maintain regular contact with the subrecipient regarding the technical aspects of the project.
  • Ensure that all deliverables (e.g. technical, equipment, and invention reports) required under the subaward are being provided and reviewed.
  • Participate in audits, site visits or other monitoring activities if necessary to review fiscal and programmatic records and/or observe programmatic activities.
  • Facilitate closeout, i.e., final technical/programmatic reports and final invoice. PIs should not approve final payments until all reports have been received.
  • Maintain documentation to support monitoring activities.

The Grants and Contracts Office:

  • Verify on an annual basis that the subrecipient has completed an OMB Single Audit (formerly known as A-133 audit), as applicable.
  • Follow-up to ensure subrecipient takes timely and appropriate corrective action when deficiencies are detected through audits, on-site reviews and other means that are related to the federal subaward issued by the University.
    • If the subrecipient does not respond in a timely manner, GCO will contact the pre-award office, PI and business manager. Future and/or final payments on any current agreements may be withheld until the subrecipient satisfactorily responds.
  • Issue a management decision for audit findings that are directly related to federally-funded subawards issued by the University.
  • Perform audits, desk reviews and other monitoring activities as determined necessary.
  • May establish its own requirements, as necessary, to ensure compliance by foreign or for-profit subrecipients, since the Single Audit provisions in OMB Circular A-133 or the Uniform Guidance do not apply to such subwards;
    • Methods to assess compliance with federal subawards made to foreign or for-profit subawards may include audits, desk reviews or other monitoring activities.

Last Updated: January 3, 2019 | Approved: Senior Associate Vice President for Business and Finance - July 7, 2015

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