Subrecipient Monitoring at UF
Subrecipient monitoring is a shared responsibility at the University of Florida, with the Principal Investigator having the lead role in monitoring the programmatic and financial activities of a subrecipient.
Below is a summary of Subrecipient Monitoring Roles and Responsibilities;
Principal Investigator (PI)
PIs have the primary responsibility for subrecipient monitoring. With each new subaward, DSP sends the PI a Subrecipient Monitoring Letter that covers the following topics:
- Maintain regular contact with the subrecipient’s PI.
- Monitor subrecipient’s technical and programmatic activities.
- Collect, review and retain subrecipient’s technical/performance reports as required by the terms of the subaward.
- Verify the subrecipient work is conducted in a timely manner and that the results delivered are in line with the proposed statement of work.
- Review and approve subrecipient invoices, including expenditures to ensure the charges are allowable, allocable, reasonable, and within the period of performance
- Approve the final invoice only when all required reports have been obtained.
- Maintain documentation of monitoring.
- Promptly contact Contracts and Grants Accounting Services with concerns about subrecipient expenditures or DSP with any indication that the subrecipient is not fulfilling its obligations under the subaward.
Department Fiscal/Grant Administrators
The level of involvement of Department fiscal or grant staff support varies, however it should be clearly defined at the local level and include the following:
- Assist PIs in their subrecipient monitoring responsibilities.
- Assist in the review of subrecipient invoices to ensure invoices are within the parameters of the subaward budget and questioning expenditures if necessary.
- Ensure subrecipient invoices are approved by the PI and returned to Contracts and Grants Accounting Services on a timely basis.
- Requesting clarification from the subrecipient regarding any unusual or excessive charges invoiced by the subrecipient.
Contracts and Grants Accounting Services
- For those subrecipient’s not in Federal Audit Clearinghouse, conducts a risk assessment using the Subrecipient Financial System Certification and Questionnaire.
- Receives invoices for payment from Subrecipients.
- Issues and collects PIs approval to pay invoice using the subrecipient payment certification form.
- Assists in the reviews of invoices prior to payment to ensure that all invoices are consistent, with subaward requirements, costs are within the project period, review invoices for unallowable costs and other inconsistencies; and ensure cumulative amount of the invoice does not exceed the total amount of the subaward.
- Provides assistance to PIs and Department staff in the event budgetary/financial issues that may arise during the period of performance.
- Works with PI, Department staff and subrecipient to resolve outstanding financial matters.
- Reviews OMB Circular A-133 reports for subrecipients or obtains an annual certification from each subrecipient for compliance with the Circular.
- Follows up on instances of subrecipient noncompliance with annual certification requirements.
- Follows up with Subrecipients regarding appropriate and timely corrective action on audit findings specifically related to a UF outgoing subaward.
Division of Sponsored Programs – Outgoing Subaward Team
- Consults with the PI and/or Department staff on all aspects of the outgoing subaward process.
- Collects any additional information necessary to complete an outgoing subaward.
- Prepares the appropriate outgoing subaward document and any amendments thereafter.
- Ensures outgoing subawards are complete and incorporate sponsor flow-down provisions.
- Ensures outgoing subawards are in compliance with the federal regulations.
- Finalizes the subaward and collects authorized official signatures.
- Distributes fully signed subaward and any amendments thereafter to PI, Department staff, and C&G Accounting Services.
- Works with PI in the event subrecipient performance or programmatic issues arise during the period of performance; works with subrecipient to identify and implement a corrective action plan; notifies sponsor as needed.