Contracts & Grants Accounting

Subrecipient Monitoring

As the prime recipient of a grant, UC Davis, may collaborate with other institutions, known as subrecipients, who carry out a portion of the project. Subrecipients can receive funding in the form of a subaward from the prime award.

Federal guidance requires prime recipients of federal funds to monitor subawards to ensure subrecipients meet the audit requirements and use funds in accordance with applicable laws, regulations and terms of the award.

UC Davis is therefore responsible for monitoring the programmatic and financial activities of its subrecipients in order to ensure proper stewardship of sponsor funds. Policy and Procedure Manual (PPM) section 330-31 addresses institutional responsibilities and assists Principal Investigators and staff to ensure that, in addition to achieving performance goals, subrecipients comply with Federal laws and regulations and with the provisions of any agreements that govern the subaward. PPM 330-31 applies to all subawards issued under sponsored programs made to the University, without regard to the primary source of funding.

Responsibilities

  • Principal Investigator (PI) or Project Director (PD) will monitor subaward performance to ensure compliance with award terms and conditions and satisfactory performance of the subrecipient's portion of the project.
  • PI/PD should review technical performance reports or other specified deliverables on a timely basis. Any unforeseen issues should be documented, investigated, and resolved.
  • PI/PD and local administrator(s) should perform an expense-to-budget comparison for cost-reimbursement subagreements.
  • PI/PD will review and authorize payment of subrecipient invoices to verify the completeness and acceptability of work performed, reasonableness of expenditures, and fulfillment of any cost-sharing commitments.
  • Subrecipients not subject to Circular A-133 may require additional monitoring by local administrators to ensure compliance.
  • PI/PD and/or local administrator may at their discretion conduct on-site visits to evaluate compliance with the project's scientific objectives, and the appropriateness of the subrecipient's administrative systems, processes and charges.
  • Sponsored Programs Office (SPO) will process subawards, ensuring specific prime award identification and contract provisions flow down into the subaward. SPO will also perform A-133 monitoring for new award applications and amendments.
  • Contracts & Grants Accounting (CGA) will review subrecipient payment requests for evidence of PI authorization.

Reviewing Invoices

There are two options for PIs to assess whether payments to subrecipients are appropriate and document their approval.

  • PI reviews and approves invoice, documenting with signature on the invoice. The invoice is scanned into the financial system as support for the payment, or
  • PI reviews and approves the invoice, and communicates the approval via email. The invoice and email approval are scanned into the financial system as support for the payment.

PIs and Administrative Units must be prepared to demonstrate their compliance with the subrecipient monitoring policies in PPM 330-31.

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