UW Research
Policies, Procedures and Guidance

UW Statement on Foreign Subrecipient Assessment, Tracking, and Monitoring

PIs can use this information to help address requests from sponsors, however in responding the PI must also include the steps they have taken to monitor progress (such as reports, site visits, calls, etc.) and how the PI decides on invoice approval in accordance with progress and consistency with the budget and sponsor policy on allowable costs

The University carries out both entity level monitoring and program level monitoring. All steps are compliant with Uniform Guidance.

All subawards, foreign and domestic, are tracked; Subaward agreements are maintained in our System for Administering Grants Electronically (SAGE), reported as required per FFATA, and tracked in the Financial System as described here.

Entity level monitoring:

  • Initial entity level assessment and certification (we have a specific form for foreign subrecipients) form to assess whether UW will enter into a subaward with entity:
    • SAM registration
    • F&A rates (NICRA or de minimis)
    • Fringe benefit rates and basis for calculation
    • Conflict of interest
    • Debarment, Suspension information of organization or employees
    • Audit status (subject to single or program-specific audit requirements)
    • Copy of audit and/or financial statements
    • Cash Management
    • Payroll
    • Procurement system
    • Property Management
    • Cost Transfers
    • Cost Sharing tracking
  • Initial project level certification form:
    • Involvement of human subjects and protocol information
    • Involvement of animals and protocol information
    • Cost sharing or matching
    • Any equipment purchases or government furnished property and description for monitoring, inventory and reporting
    • SFI disclosure policy
  • Risk Assessment:
    • Risk assessment matrix used per subrecipient for entity level considerations such as organization type, maturity of organization, audit reports, accounting system used, and other factors that may be specific to the work to be carried out. If an entity is medium or high risk, UW will evaluate whether special terms should be included in agreements to mitigate risk.
  • Excluded Party Screening:
    • Prior to committing funds by signing a new subaward or a subaward modification, UW carries out excluded party screening.
  • Issues one year at a time:
    • The UW does not issue multi-year subawards but carries out an annual renewal to ensure there is annual subrecipient single audit review, to reconfirm nonfiscal compliance approvals in place, and to review any terms and conditions to flow down in the next year’s subaward terms.
  • Specific foreign entity subaward template:
    • The UW uses a specific template for foreign subrecipients that can be customized further, to include prime award requirements, and additional monitoring steps such as additional reporting or site visit information, as applicable and when requested by the PI. The language requests invoicing monthly, but requires invoicing no less frequently than quarterly and we have alternative language requiring monthly when the risk assessment warrants it.
  • Reporting requirements:
    • Subaward terms reflect the reporting required by the prime, and may include additional terms as required by the nature of the work and needed by the UW PI on the schedule that backs up invoices.
  • Invoicing:
    • Invoicing monthly, but no less frequently than quarterly is standard; we have alternative language requiring monthly when the risk assessment warrants it.
  • Single audit verification:
    • The UW carries out annual single audit verification and certification, when applicable.
  • Financial System controls:
    • The financial system is set-up to require: Acceptance of the prime terms prior to subaward request to OSP; approval of subaward terms and acceptance by subrecipient prior to any PO issuance; have one award line per subaward under an award; requirement that the PI log their approval of invoices (no delegation of this function).

The UW will carry out increased oversight if a Management Decision is in place (see Uniform Guidance).

Please also see UW Policies GIM 7 (Sponsored Program Subaward Administration) and GIM 8 (Subrecipient Monitoring).