Subrecipient Monitoring

What is Subrecipient Monitoring

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.

The University must consider:

• Subrecipient’s prior experience (including lack of performance)?
• Is Subrecipient debarred or suspended?
• Does the Subrecipient require cash advances?
• Does the Subrecipient have trustworthy accounting systems? Effort system? Property Management Systems?

Subawards to foreign institutions, especially those with little or no history of U.S. federal funding present greater risk and will likely require additional monitoring.

Subrecipient Monitoring Roles and Responsibilities are identified below.

Principal Investigator (PI)

PI’s have the primary responsibility for subrecipient monitoring. With each UFIRST executed subaward, DSP includes a reminder that covers the following topics:

• Maintains regular contact with the subrecipient’s PI.
• Monitors subrecipient’s technical and programmatic activities.
• Collects, reviews and retains subrecipient’s technical/performance reports as required by the terms of the subaward.
• Verifies the subrecipient work is conducted in a timely manner and ensures the results delivered are in line with the proposed statement of work.
• Reviews and approves subrecipient invoices to ensure the charges are reasonable.
• Approves the final invoice, only when all required reports have been obtained.
• Promptly contacts C&G with concerns about subrecipient expenditures or DSP with any indication 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:

• Assists PI’s in their subrecipient monitoring responsibilities.
• Assists in the review of subrecipient invoices to ensure invoices are within the parameters of the subaward budget and questions expenditures if necessary.
• Ensures subrecipient invoices are approved by the PI and returned to C&G on a timely basis.
• Requests clarification from the subrecipient regarding any unusual or excessive charges invoiced by the subrecipient.

Division of Sponsored Programs

• Conducts risk assessment for all new subawards.
• Prepares the appropriate outgoing subaward and any modifications. Ensures outgoing subawards incorporate appropriate provisions including additional requirements to mitigate risk.
• Provides assistance to PI’s and department staff with any issues that arise during the period of performance.
• Works with PI’s in the event of any subrecipient performance or programmatic issues.

Contracts and Grants Accounting Services

• Receives invoices from Subrecipients and coordinates approval to pay with PI.
  • Reviews invoices before payment to ensure consistency with subaward requirements.
  • High Risk Invoices are reviewed by the C&G accountant with additional scrutiny.
  • Review of Cost Sharing expenses are documented on the Subrecipient invoice. Ensure they are flagged for the UF Principal Investigator/Department for review.
• Provides assistance to PI’s and department staff with any financial issues that arise during the period of performance.

Reviews each Subrecipient’s annual Single Audit report as required by Uniform Guidance. If the subaward or Subrecipient is not subject to Uniform Guidance, obtains an annual certification from each subrecipient for compliance. If the Subrecipient has audit findings related to a subaward from UF, follows up with subrecipients regarding corrective action.

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