When the University issues a subaward to another entity, the University must monitor the subrecipient to ensure compliance with award terms & conditions, sponsor policy, university policy, and local, state and Federal laws. Subrecipient monitoring is a shared responsibility among the Principal Investigator (PI), Business Manager, the Office of Sponsored Programs.
The OBFS Sponsored Projects Subawards policy describes when a subaward may be issued and how the associated responsibilities are divided. The policy also includes:
- Responsibilities to Monitor a Subrecipient – more detail on the responsibilities of the PI/Business Manager and OSP
- Guidelines on Subrecipient Performance – how monitoring is conducted and actions that may be taken for unsatisfactory performance
- Procedures for reviewing and paying subrecipient invoices and closing subawards.
The Principal Investigator 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 cost 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, and invention reports) 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 and final invoice. PIs should not approve final payments until all reports have been received.
- Maintain documentation to support monitoring activities.
- Review terms & conditions of award (PI or designee)
- Receiving deliverables & invoices on time (technical reports)
- Review to make sure consistent with progress & sign off on invoices (invoicing checklist)
- Maintain documentation on file (document the performance of the subrecipient – see checklist for examples)
Concerns About a Subrecipient
The Principal Investigator or department staff should promptly contact OSP with any concerns about a subrecipient including:
- Suspicion of subrecipient non-performance, (e.g., late progress reports)
- Fraud or non-compliance
- Any indication that the subrecipient is not fulfilling the obligations under the subaward
If the PI intends to terminate the award early, the PI or business manager should notify OSP so written notification can be provided to the subrecipient.
- OBFS Policy Sponsored Projects Subawards
- Review and Pay Subrecipient Invoices
- Close a Subaward
- Guidelines on Subrecipient Performance
- Responsibilities to Monitor a Subrecipient
- Subrecipient Monitoring Checklist
- Subrecipient Monitoring Invoice Checklist
- RAMM Presentation on Subawards & Subrecipient Monitoring
- Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards – Subrecipient Monitoring and Management
An award that passes from one entity to another. It is a legal agreement issued by the prime recipient (e.g. UIC) to another entity (e.g. another university) to perform portions of the work as outlined in the funded proposal.
Important: A subaward does not involve the procurement of goods or non-research services.
Legal entity to which a subaward is made. The subrecipient is accountable to the prime recipient (e.g. UIC) for the appropriate use of the funds provided.