5.3 Subrecipient Monitoring

Principal Investigator (PI) / Project Director (PD) 

PI/PDs have primary responsibility for monitoring Subrecipient technical and financial performance to ensure Subrecipients use sponsored funds for authorized purposes in compliance with applicable federal regulations and the terms and conditions of the Subaward and achieve performance goals. This includes:

• If required, performing a cost price analysis.
• Reviewing financial and performance reports required in the Subaward and maintaining contact and coordination with Subrecipient technical personnel.
• Verifying the Subrecipient’s work is conducted in a timely manner and that the results delivered are in line with the proposed statement of work. 
• Reviewing Subrecipient invoices and approving for payment only if charges are for authorized purposes. This consists of ensuring charges are reasonable in comparison to performance and performance is consistent with the proposed statement of work. 
• Notifying the Office of Sponsored Program of any Subrecipient Risk factors, including any actual or potential conflict of interest, and ensuring the Subrecipient has complied with any additional conditions of the Subaward.
• Complying with the Institute’s Project Close Out Policy.

Unit Financial Officers (Departmental Administrators) 

• Assisting PI/PDs with their responsibilities listed above, including maintaining documentation of monitoring actions (evidence of technical, financial, and invoice review, copies of email, notes from phone conversations, etc.). Documentation of monitoring actions must be kept in accordance with the Institute’s document retention policy. 
• Reviewing invoices from Subrecipients to ensure they are within the parameters of the Subaward budget and period of performance.
• If expenditure details are a requirement of the Subaward, reviewing for reasonableness and requesting and reviewing additional information if questionable expenditures are identified.
• Assisting PI/PDs in determining whether invoices should be approved.
• Ensuring invoices that are approved by the PI or his/her designee are submitted to Accounts Payable on a timely basis.
• Complying with the Institute's Project Close Out Policy.

Office of Sponsored Programs (OSP) 

OSP is responsible for ensuring that the Institute’s Subrecipient Monitoring and Management policies are sufficient for the Institute to fulfill its responsibilities for compliance with federal, state and other sponsor requirements. Related OSP responsibilities include: 

• Identifying to the Subrecipient the Federal award information as required in section 2 CFR 200.332 (Federal Award Identification Number, etc.) and applicable compliance requirements, including any appropriate flow-down provisions from the prime agreement.
• Ensuring the selection of subrecipient is documented and, if required, that the PI/PD and Unit performed a cost price analysis.
• Determining, as applicable and in compliance with 2 CFR 200.206(d), whether or not the subrecipient or its PIs are debarred or suspended from receiving Federal funds.
• Evaluating each Subrecipient’s risk of noncompliance with applicable Federal statutes, regulations, and the terms and conditions of their Subawards.
• Determining, based on the above evaluation, appropriate Institute Subrecipient Monitoring, including tools listed in 2 CFR 200.332(e), and whether to impose additional conditions, such as those listed in 2 CFR 200.208 (c), to mitigate risk.
• Verifying that every Subrecipient meeting the criteria in 2 CFR 200 Subpart F – Audit Requirements is audited as required.
• Assisting Grants and Contracts Accounting in considering whether the results of any Subrecipient's audits, on-site review, or other monitoring indicate the need for an adjustment to the Institute’s records.
• For Federally funded Subawards, ensuring that the Subrecipient takes timely and appropriate action on any deficiencies pertaining to the Subaward detected through audits, on-site reviews, and/or written confirmation from the subrecipient, highlighting the status of actions planned or taken to address findings related to the particular Subaward. 
• For Federally funded Subawards, issuing a management decision for applicable audit findings pertaining only to the particular Subaward, as required by 2 CFR 200.521. 
• Coordinating compliance with the Institute’s Project Close Out Policy.

The above list is not exhaustive of all compliance requirements. In addition to the general elements of compliance noted above, there may be additional sponsor- or program-specific requirements that mandate collecting and documenting other assurances (e.g. on lab animals, human subjects, biohazards, export controls, financial conflicts of interest, etc.) during the course of a project. PI/PDs and department administrators will have additional roles and responsibilities, as applicable, to ensure compliance with any additional requirements of a sponsor- or program-specific requirement.