16.5.4 Responsibilities to Monitor a Subrecipient
The Principal investigator (PI), the unit business manager, and the university sponsored programs office share the responsibility of monitoring subrecipients.
The PI 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 costs 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, invention reports, and the like) 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, final invoice, and the like). PIs should not approve final payments until all reports have been received.
- Maintain documentation to support monitoring activities.
The University Sponsored Programs 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, the sponsored programs office 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 subawards;
- Methods to assess compliance with federal subawards made to foreign or for-profit subawards may include audits, desk reviews, or other monitoring activities.
Additional Resources
Info on OMB Single Audit
OMB Circular A-133
First Published: July 2015 | Last Updated: March 2024 | Last Reviewed: March 2024