Research Topic

Subaward Monitoring

  1. Guidance & Resources
  2. Sponsored Research Topics and Guidance
  3. Subaward Monitoring
  4. Subaward Monitoring

Description

Responsibility for monitoring subrecipients is a joint effort between the principal investigator, the departmental/unit administrator, and SPA. If the PI has concerns about either the performance or amount invoiced by the subrecipient, they should be shared timely with SPA, so the concerns can be addressed, which may include withholding payment.

  • Verify that work performed by the subrecipient is conducted in a timely manner and is acceptable.
  • Review and compare subrecipient invoices to established budgets, including cost share commitments, to ensure cost are reasonable, allowable, allocable and consistently treated during life of subaward. 
  • Certify/approve all subrecipient invoices and submit for timely payment.  Federal regulations require invoices are paid within 30 days of receipt.
  • Maintain regular contact with the subrecipient regarding the technical aspects of the project and ensure all deliverables (e.g. technical, equipment, and invention reports) required under the subaward are being provided and reviewed.
  • Participate in audits, 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 the final invoice until all reports have been received.
  • Maintain documentation to support monitoring activities.
  • Perform suspension and debarment review on subrecipient entity and PI
  • Perform pre-award risk assessment prior to issuing subaward agreement
  • Verify on an annual basis that the subrecipient has completed a Single Audit as required by Uniform Guidance.
  • Follow up to ensure subrecipient takes timely and appropriate corrective action when deficiencies are detected through audits and other means that are related to the subaward issued by the University.
  • Perform audits, desk reviews, and other monitoring activities as determined necessary.
  • In instances when the subrecipient does not respond timely, SPA communicates internally and may contact the PI/unit business manager for assistance. Future and/or final payments on any current agreements may be withheld until the subrecipient satisfactorily responds.
  • Establish its own requirements, as necessary, to ensure compliance by foreign or for-profit subrecipients not subject to Uniform Guidance/Single Audit Act. Methods to assess compliance with subawards may include audits, desk reviews, or other monitoring activities.

 Additional Guidelines on Subrecipient Performance

The Principal Investigator (PI) is responsible for ensuring that the progress on the subrecipient’s scope of work is satisfactory. The PI should manage each subrecipient's work or progress as presented in the subaward proposal, and as awarded by reviewing the subrecipient’s technical reports or other deliverables related to the project. Progress may also be reviewed through other communications, meetings, publications, etc.

Programmatic Reports

The subrecipient is responsible for completing programmatic reports as stipulated in the terms and conditions of the subaward. Programmatic reports should be submitted by the subrecipient to the PI, as applicable. Programmatic reports serve as official documentation that the stated work has been performed, and substantiate the invoices paid throughout the course of the funding period. These reports should be maintained by the PI/department.

Unsatisfactory Performance

The PI determines the validity of the subrecipient invoices based upon the progress of the subawardee. The PI reserves the right to reject or withhold an invoice due to insufficient or unsatisfactory performance. If there are concerns about either the subrecipient’s performance or invoices, contact SPA as quickly as possible for assistance in resolving the issue.  In the event the performance issue is unable to be resolved, please review stop work order and early termination actions below.

Stop Work Order/Suspension

In the case of unsatisfactory performance by the subrecipient or non-compliance with the terms and conditions of the subaward agreement, SPA Pre-Award may, when appropriate, unilaterally issue a stop work order which is usually done through a written notification signed by the authorized official. Stop work orders are temporary and may affect all or only a part of the subrecipient work and should only be used until a more formal action can be taken to resolve the problem or dispute. Stop-work order should include:

(a) a description of the work to be suspended;

(b) the maximum duration of the suspension;

(c) instructions regarding minimization of costs during the suspension; and

(d) any other actions to be taken by the subrecipient.

If PI or departmental staff have concerns with performance, please start with your award management contact to discuss appropriate next steps in accordance with the award terms and conditions.

Early Termination

If the subrecipient is in violation, breach, or default of any of its obligations under the subaward and fails to remedy such default, the PI has the option to request termination of the subaward. The PI or business manager shall notify SPA Pre-Award of the intent to terminate the award early so written notification signed by the authorized official can be provided to the subrecipient.

Upon early termination, the subrecipient will be required to submit a final invoice within 30 days of the termination date unless otherwise stated in the termination notice or the subaward agreement. The subrecipient will be reimbursed for allowable, non-cancelable costs and commitments incurred in the performance of the subaward up to the termination date, not to exceed the maximum reimbursement amount set forth in the agreement. Additionally, the subaward’s PI must submit all necessary progress reports through the date of termination.

 

Related Policies

Revised Date