UW Research

Policies, Procedures and Guidance

GIM 08 – Subrecipient Monitoring

Effective January 1, 2016

Purpose

The University of Washington (UW) has a long tradition of working closely with collaborative institutions, non-profits and industry partners on sponsored programs. These relationships often take the form of a pass-through entity (UW) and a subrecipient (collaborator). This GIM directly relates to Sponsored Program Subaward Administration GIM 7 which addresses policy and outlines procedures for the administration of subawards issued by the University under a prime agreement (contract, grant or cooperative agreement) awarded to the University.

When UW issues a subaward to a subrecipient, there is an initial and on-going responsibility to ensure the subrecipient entity is qualified to carry out the activity, is in compliance with the originating (prime) sponsor requirements, the subaward agreement and UW policy, and provides regular and timely invoicing, reporting and other documentation as set out in the subaward agreement. This responsibility is shared among central administration, the UW Principal Investigator, and the department administrative staff.

Background

At the time of proposal submission, UW represents to the prime sponsor that all activity, including that of the subrecipient, will be carried out consistent with sponsor requirements. Additionally, per the Federal Uniform Guidance, UW must evaluate each subrecipients’ risk of noncompliance with federal regulations, include specific terms and conditions in the subaward as necessary, and monitor the activities of the subrecipient through various mechanisms. These mechanisms include: Training and technical assistance to subrecipients, on-site reviews, review of audit results, increased reporting requirements and enforcement action, if necessary.

University Policy

UW reviews each subrecipient entity according to an entity level comprehensive risk assessment prior to the issuance of a subaward. This risk assessment includes an entity level review of their fiscal systems, past audit activity, and if required, financial statements of the entity as well as the project specific activity proposed and that the required compliance approvals are obtained. When necessary, UW imposes limitations and requirements on the subrecipient through subaward terms and conditions per Federal Uniform Guidance, Section 200.521, prior to the issuance or renewal of a subaward.

UW’s subrecipient monitoring requirements are comprised, at a minimum, of the following:

  • Completion of the UW’s entity level comprehensive risk assessment (Certs & Reps, Annual Audit Certification);
  • UW approved systems must be used to request issuance, renewal or modification of a subaward;
  • Receipt and acknowledgement of outgoing subaward terms and conditions;
  • Receipt of regular progress reports from subrecipient;
  • Approval/rejection of subrecipient entity’s invoice through approved UW systems;
  • Tracking of cumulative totals of subaward invoices;
  • Maintain a record of the subaward agreement, subrecipient entity progress reports, approved invoices, back-up documentation & any delegation of authority relevant to approval of subrecipient materials, within prime award file.

OSP may require a documented subrecipient monitoring plan signed by the UW PI prior to issuance of the subaward, on a case by case basis, at OSP’s discretion.

Under no circumstance will UW execute a subaward agreement or modification in which the subrecipient entity is found to be a high risk subrecipient that has not provided required compliance documentation or the subrecipient entity has not provided necessary information or documentation to successfully carry out a full risk assessment.

Potential cases of non-performance, non-compliance, or subaward interpretation disputes with the subrecipient shall be escalated by the UW PI to the Subawards Team, Office of Sponsored Programs (OSP), if the issue cannot be resolved between the UW PI and subrecipient PI, OSP may involve the Human Subjects Division, the Office of Animal Welfare, Accounts Payable, the Office of Research, the Prime Sponsor, other UW offices or Federal agencies, or the Washington State Attorney General’s office as applicable.

Roles & Responsibilites

PI / Department Responsibilities

Project level monitoring of subrecipient including:

  • Monitor subrecipient technical progress & performance.
  • Monitor subrecipient adherence to terms & conditions.
  • Provide & follow subrecipient monitoring plans as requested based on OSP’s discretion on cases by case basis.
  • Verify compliance approvals are current for subrecipient portions of the statement of work.
  • Reviews that expenses are necessary, reasonable, and allocable to the work completed and are aligned with technical progress.
  • Ensure that all required reports are received.
  • Approve invoices for payment.
  • Work closely with subrecipient to ensure timely invoices. Late invoices received past the close date set out in the terms & conditions are subject to rejection.
  • Site visits, regular teleconferences, and / or the use of checklists by the PI with the subrecipient PI are advised for multi-year collaborations.
  • Escalate potential cases of non‐performance, non‐compliance, or subaward interpretation disputes with the subrecipient to the Subawards Team, Office of Sponsored Programs.

OSP Responsibilities

  • Perform subrecipient risk assessment.
  • Incorporate special terms & conditions based on subrecipient entity risk assessment.
  • Entity level monitoring on annual or as needed basis.
  • Issue a management plan to subrecipient in accordance with Uniform Guidance.
  • Request & approve subrecipient monitoring plans for PI/Dept. to follow on cases by case basis at OSP’s discretion.
  • Verify that corrective action plans have been implemented by subrecipient as necessary.
  • Review escalation requests & take appropriate action which may involve coordination with the Human Subjects Division, the Office of Animal Welfare, Accounts Payable, the Office of Research, the Prime Sponsor, other UW offices or Federal agencies, or the Washington State Attorney General’s office as applicable.

Subrecipient

  • Complete certification forms including annual audit request forms
  • Perform & comply with applicable terms, conditions, regulations & deadlines

Procedures and Guidance

Subrecipient Risk Assessment

Before a subrecipient receives a subaward from UW, UW reviews the subrecipient on two levels:

  • Entity Level Fiscal Review
  • Project Level Review

The Entity Level Fiscal Review consists of ensuring the subrecipient, as an entity, has the necessary structure, policies, systems and controls in place to manage the sponsored project funding. This is achieved through reviewing the entity’s financial “health” by collecting necessary information about the entity through a Subrecipient Certification form.

The Project Level Review consists of collecting necessary information from the subrecipient regarding specific project compliance approvals such as IRB approval, IACUC approval, a copy of the SFI policy and SFI disclosures, SFI management plans, and any additional certifications from the subrecipient that satisfy our documentation needs and the terms of the prime award.

UW checks that a subrecipient entity is not debarred, suspended or otherwise ineligible to participate or do business with UW.

Subrecipient Monitoring – Project Level

Subrecipient monitoring is carried out at the project level, in addition to entity level monitoring.

The UW PI is responsible for monitoring that the subrecipient is making progress towards the performance goals of the project; that costs associated with the progress are necessary, reasonable, and allocable to the work completed; that invoiced amounts are tracked; and that the activity carried out is in compliance with the terms and conditions of the subaward, such as the stated scope of work, timeline and budget.

Receipt of regular progress reports are a key component of project level monitoring. The frequency of such reporting is indicated in the subaward agreement and the PI, as the recipient of such reports, is best positioned to ensure the reports reflect that performance goals are achieved.

The UW PI receives reviews and approves/rejects subrecipient invoices in the manner and frequency stated in the subaward. While receipt and approval of the invoice in the UW Procurement System (ARIBA) may be carried out by the PI’s delegate, the internal documentation on the project must reflect that a process is in place to achieve PI’s approval that the invoice reflects reasonable, allocable and necessary costs.

Tracking of the cumulative costs associated with the subaward is done at the project level, and the UW ARIBA system, and the UW financial system, are two tools available to ensure that there are not cost overruns by the subrecipient.

In some cases, a documented subrecipient monitoring plan, signed by the PI, will be required due to the risk assessment determination by OSP. The OSP subaward team staff will work with the PI on establishing what this plan must consist of in order to effectively monitor activities of the subrecipient. Such a plan may involve site visits for programmatic and regulatory/fiscal review, onsite training, increased frequency of reporting requirements, and timelines to request results for any particular corrective actions imposed through the subaward agreement.

If changes to the subaward terms and conditions are needed, or if suspension, termination or other measures to postpone payment are needed, all changes should be processed through OSP as set out in GIM 7.

Subrecipient Monitoring – Entity Level

Subrecipient monitoring is necessary, from the issuance of the subaward through to closeout.

Entity level monitoring consists of a combination of the following:

  • Initial Subrecipient Certification Form completion and assurance by subrecipient’s authorized official
  • Annual audit assurance through an annual audit certification form
  • Maintenance of a subrecipient profile list, which includes information on the entity’s past audit information and certifications
  • Risk assessment carried out at each annual renewal of a subaward

Other steps, such as implementation of training on regulatory requirements or internal controls, or on-site reviews, may be implemented, as part of on-going monitoring and review.

If an entity has an audit finding, the finding is reviewed to determine if the findings are related to the funding that has or will be issued under a subaward, and ensure appropriate corrective action is in process, if related. A Management Decision, per Federal Uniform Guidance, §200.521, may be issued due to the severity of the finding or associated other factors, and in all cases, is issued when audit findings relate to federal award funding that has been or will be issued under a subaward.

Invoicing by Subrecipient and Approval of Invoices

Invoices from the subrecipient are submitted and approved through the UW Procurement system.

The invoice is submitted under a Blanket Purchase Order (BPO) that has been created in the system for the subaward. Details of the BPO are available in the system. The invoice number, date, quantity, price, description of costs and other details are entered by the subrecipient entity and appropriate invoice attachments as required by the subaward agreement are provided in the system. Detailed information about invoicing is in the subaward agreement. Procurement Services has guidance on the website for all suppliers on how to submit invoices.

Upon the subrecipient’s submission of the invoice, the UW department can then review, and if appropriate, approve the invoice in the system. When approving an invoice, the department is actually approving an amount of money to be released for payment of the invoice. The individual approving the invoice in the system must have the appropriate UW ASTRA role to perform this function.

The individual(s) approving the invoice in the system must have the delegated authority to do so from the PI on the sponsored program, per GIM 2 signature delegation procedures, or obtain written approval of the invoice from the PI or individual with such delegated authority. More information about approving or rejecting an invoice is provided by the UW Procurement Services office.

Final Closeout of Subaward

It is important that UW receive final reports from the subrecipient in accordance with the terms and conditions of the subaward so that the UW can submit final reports on the prime award by the prime sponsor deadline.

Reporting requirements are set out in the subaward, including the requirement for submission of the final invoice, technical report and other reports as may be necessary to fulfill the reporting requirements of the prime award. It is advisable for the UW PI to notify his/her subrecipient PI counterpart to initiate the closeout process well in advance. A checklist and timeline of recommended final closeout steps is available in GIM 39.

Late invoices submitted by the subrecipient are subject to nonpayment.

Definitions

Subaward:

Binding legal contract between UW and another institution or entity regarding completion of part of a sponsored program.

Subawardee, subrecipient:

Institution receiving a subaward or subcontract from prime institution.

Related Resources

Subject Resource Link
Office of Sponsored Programs: Subawards Set Up Subawards and Manage Subawards
Sponsored Program Subaward Administration GIM 7
Monitoring the prime sponsor budget number MyFinancial Desktop
Procurement Services Ariba System for Receiving Orders

Content Creator

Office of Sponsored Programs

Review Schedule

This policy is reviewed by the Office of Sponsored Programs as necessary to reflect changes in Federal regulation or University policies.