Georgia Tech is responsible for ensuring that all subrecipients of its sponsored research awards are in compliance with applicable requirements in accordance with 2 CFR 200 Subpart D Subrecipient Monitoring and Management and Subpart F – Audit Requirements, when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equals or exceed $750,000 (2 CFR 200.501). These guidelines and procedures are provided to assist faculty and staff in ensuring that subrecipients conduct their portions of research projects in compliance with laws, regulations and terms and conditions of awards and subawards and that project costs incurred by subrecipients are reasonable and allowable.
Roles and Responsibilities
Principal Investigators (PI)
PIs have primary responsibility for monitoring subrecipient's technical and financial performance to ensure compliance with federal regulations and both prime and subrecipient award terms and conditions. The Federal Government places the primary responsibility for management of federally funded projects with the PI. This includes:
- Monitoring of subrecipient’s programmatic and financial activities related to the sub-award.
- Review of technical/performance reports as required.
- The PI is responsible for verifying the subrecipient work is conducted in a timely manner and that the results delivered are in line with the proposed statement of work.
- The PI is responsible for reviewing and approving subrecipient invoices. This includes reviewing expenditures to ensure the charges are allowable, allocable, reasonable, and that the charges are within the period of performance.
- The PI is responsible for maintaining regular contact with the subrecipient.
Unit Financial Officers (Departmental Administrators)
- Reviewing invoices from subrecipients to ensure invoices are within the parameters of the sub-award budget, and questioning expenditures if necessary.
- Ensure that invoices are approved by the PI or his/her designee and submitted to Accounts Payable in a timely basis.
- If there are any unusual or excessive charges invoiced by the subrecipient, the department should request clarification from the subrecipient.
- Maintain copies of all invoices that provide evidence of the regular review of invoices by the PI. “Evidence” can be in the form of authorized signature by the PI or his/her designee, PI’s initials, e-mail communications, or notes of meeting between the PI with the department administrator.
- Maintaining documentation of monitoring efforts (copies of e-mail, phone log, etc.).
Unit Financial Officers (UFO’s) should assist PI’s in carrying out their subrecipient monitoring responsibilities. This includes:
Office of Sponsored Programs (OSP)
OSP is responsible for the oversight of subrecipient monitoring and ensuring that the Institute’s subrecipient monitoring procedures are compliant with federal and other applicable regulations. These responsibilities include:
- Identifying to the subrecipient the Federal award information as required in section 2 CFR 200.331 (e.g., CFDA title and number, award name, name of Federal agency) and applicable compliance requirements, including any appropriate flow-down provisions from the prime agreement.
- Ensure the use of subrecipient is well documented and cost price analysis performed in accordance with applicable regulations.
- Determining whether or not the subrecipient or its PI’s are debarred or suspended from receiving Federal funds.
- On an annual basis, reviewing all active sub-awards for which monitoring is mandated. Accordingly, OSP requests audit certification letters from all subrecipients expending $750,000 or more in Federal funds during the subrecipient’s fiscal year.
- The returned certification letters are reviewed by the OSP Audit Coordinator to verify that no audit findings related to Federal funds provided by Georgia Tech are reported. If no findings are indicated, the OSP Audit Coordinator will initial, date, and notate that no follow-up action is required. OSP will inquire further into those that are deemed to require closer scrutiny, and take appropriate action.
- Add additional conditions to the subaward when appropriate in accordance with 2 CFR 200.207 to manage any risk posed by subrecipient.
- In accordance with FAR 52.219-9(d)(9), for Subrecipients under Federal Contracts, when a subcontract is awarded to a subcontractor (other than a Small Business) and is in excess of $750,000, OSP will obtain a Subcontracting Plan from the subcontractor.
- In accordance with FAR 52.215-12, will obtain from the subcontractor a Certificate Cost or Pricing Data on all subcontracts in excess of $2,000,000 on or after July 1, 2018 and issued under a Federal contract.
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. OSP will work with PIs and department administrators to establish channels of communication with subrecipients that require further scrutiny.