Who Is Responsible For Subrecipient Monitoring?
Principal Investigators have the primary responsibility for monitoring subrecipients’ technical and financial progress and ensuring compliance with Federal regulations and both prime and subrecipient award terms and conditions. This includes:
- Monitoring scientific progress and subrecipient’s adherence to terms
- Verifying that cost sharing commitments are met
- Verifying compliance approvals are current for subrecipient’s portion of statement of work (human subjects, animal subjects, biosafety)
- Approving invoices for payment
Departmental Administrators assist Principal Investigators in their monitoring responsibilities, reviewing subrecipient invoices, identifying and following up on questionable expenditures and, if necessary, maintaining documentation of monitoring efforts.
Department of Contracts and Grants performs a risk analysis of the subrecipient prior to issuing a subaward. If a subrecipient is found to be medium-high risk based on their Single Audit or information submitted via their Subrecipient Certification form, the subaward may include additional terms such as:
- Corrective Action Plan
- On-site monitoring
- More detailed invoicing
- Receipt of technical progress reports tied to payments
- More stringent termination language for failure to comply with requirements