Project Risk Assessment
Before executing a subrecipient agreement, and every two years thereafter, the subrecipient must complete and submit a Subrecipient Profile Questionnaire, which allows the University to identify project specific risks. Where the assessment reveals a high potential for risk, Sponsored Program Services (SPS) will propose a risk mitigation strategy before proceeding with the subaward. The risk assessment takes into account several factors, including the following:
- Type of subrecipient organization (for-profit/not-for-profit/small business/corporation/ foreign/domestic)
- Whether the subrecipient is subject to the Single Audit requirements. Subrecipients not subject to Single Audit requirements must provide more information regarding their financial status and systems as part of the Subrecipient Profile Questionnaire
- Subaward value relative to the prime award
- University’s prior relationship with the subrecipient
- Organizational and individual conflict of interest
- Necessary IRB and/or IACUC protocols
Post-Award Subrecipient Monitoring
The University is responsible for monitoring the activities of subrecipients to ensure that awarded funds are used for authorized purposes and that performance goals are achieved.
- At least annually, SPS will review subrecipient’s financial stability, financial processes, and controls as follows:
- Subrecipients subject to Uniform Guidance (UG) that expend $750,000 or more of federal funds annually are subject to Single Audit requirements. Annual Single Audit certifications are retrieved from the Federal Audit Clearinghouse. If the Single Audit is not available from the Federal Audit Clearinghouse, SPS will be request Audit Certification directly from the Subrecipient. In the event of an unfavorable audit certification, SPS will confirm that the subrecipient has taken appropriate and timely corrective action(s)
- Subrecipients not subject to Single Audit requirements must provide annual audited financial statements
- SPS will review the audit documentation and determine whether or not the Subrecipient’s risk designation requires reevaluation
Progress Monitoring, Technical Reports and Deliverables
- SPS, the responsible University PI, and department grant administrators will jointly determine the frequency and scope of departmental monitoring procedures. A “risk-based” approach to subrecipient monitoring is recommended with the frequency and intensity of monitoring driven by the terms of the prime award and the criteria identified in the section of this procedure titled Subrecipient Pre-Qualification Review.
- PIs will monitor the progress of subrecipient work scope at least on a quarterly basis
- Options for review include informal progress reports via phone conversations, e-mail communications, or face-to-face discussions, formal technical reports or other deliverables specified in the agreement required and due on specific dates. Subrecipient invoices will be submitted to the University PI
- Subrecipient is required to submit invoices adhering to the following criteria:
- Expenditures are reported for current period and cumulative period
- Expenditures are itemized by cost category
- Cost share and/or match is reported on each invoice
- Invoice must also include the following:
- Subrecipient’s name and address
- Subaward Agreement Number and University account number
- Project period and period of invoice
- Invoice number and date prepared
- Subrecipient contact person with respect to the invoice
- Certification on each invoice as to the truth and accuracy of the invoice
- Final Invoice must be submitted by subrecipient within forty-five (45) days of end date
- PI will review and approve invoices from subrecipients to ensure that:
- Expenditures are consistent with the proposed budget
- Costs are incurred within the period of performance and are allowable
- Expenses are aligned with technical progress
- Cost sharing is appropriately reflected if required
- The PI must sign the invoice to indicate that review has been completed and that the invoice has been approved for payment.
Submitting Invoices for Payment
The Principal Investigator must approve invoices for payment. This task may not be delegated.
Resolving Invoice Issues
- If PI identifies a concern with subrecipient performance, the PI will request clarification from the subrecipient PI.
- If department grant administrators identify any unusual, apparently excessive, or potentially unallowable charges invoiced by a subrecipient and if the explanations from the subrecipient are insufficient to render a prudent judgment on the allowability of the cost, the department grant administrator shall refer the matter to SPS for resolution with the subrecipient’s institutional authorities.
- When SPS is satisfied that the issues are resolved, they will notify the department and PI to proceed with approval for payment. Invoices will not be approved for payment until all issues or concerns have been resolved.
Closeout of Subawards
OVPR SPS, in collaboration with department administrators and/or PI, will begin subaward closeout actions immediately following conclusion of the subaward period of performance. Subawards will be processed for closeout and formally closed within a 60-day time period, unless SPS grants the department an extension. A subaward may not be formally closed until all of the following closeout requirements have been met:
- Final review of costs charged to the University and final close-out of all commitments, accrued costs, or payables.
- Receipt of final invoice from subrecipient and Subrecipient Release and Certification Form (Attachment C)
- Receipt of all required deliverables as specified in the subaward, patent/invention documentation, and equipment reports. Final verification of technical completion will be indicated by the PI’s signature and date on the final invoice.