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Who monitors subrecipients?
When Indiana University issues a subaward agreement on a sponsored award, several parties share responsibility for monitoring that agreement: Financial Management Services accounts payable, the principal investigator, the fiscal officer (FO) or delegate, and IU’s Office of Research Administration.
Subrecipient monitoring responsibilities
- Verify information on the invoice to purchase order
- Ensure expenses are coded to the correct object and sub object codes
- Initiate Kuali Financial System payment request document
- Scan invoice and supporting documentation
- Route payment request and documentation for approval
- Monitor appropriate program milestones being met relative to the rate of expenditure
- Review all subrecipient invoices for allowability, allocability, and reasonableness
- Collect program/technical reports in a timely manner as required by the subaward agreement and the prime funding agreement
- Verify subrecipient’s work is completed in a timely manner and is adequate compared to costs incurred
- Coordinate with the fiscal officer and subrecipient to resolve identified issues
- Review all invoices to verify that costs:
- are allowable, allocable, and reasonable
- do not exceed the amount awarded
- are incurred within the time period of the approved subaward
- Confirm the subrecipient indirect costs have been calculated correctly
- Ensure the correct IU subcontract object code and subobject code are used on payments
- Verify required additional documentation is acceptable for high-risk subrecipients
- Document the principal investigator’s approval
- Coordinate with principal investigator and subrecipient to resolve identified issues
- Pending invoices should be placed on hold or canceled
- Retain documentation of review
- See Subrecipient Invoice Checklist (Accessible 02/18/19)
Research Contracting Office:
- Subaward risk review is conducted when IU issues a new subaward or subaward amendment with additional funding. The contract officer will review the most recently completed subrecipient risk assessment. If the risk assessment is within the last 12 months, the contract officer will use that risk assessment when drafting the agreement. If the most recently completed risk assessment is more than 12 months old, the contract officer will hold the agreement until a new subrecipient risk assessment has been completed.
- Subrecipient risk assessment determines whether an audit has been completed annually for a subrecipient and identifies the risk level of the subrecipient. The subrecipient risk assessment is completed no more frequently than annually and may occur more infrequently for subrecipients which receive only sporadic funding.
Grants, Finance and Operations:
Subrecipient invoice review ensures that subrecipients identified as high-risk entities undergo further scrutiny. For this activity, Indiana University will select a sample of invoices of high-risk entities to verify the allowability of the charges on the invoices. The subrecipient invoice review is conducted throughout the year. The subrecipient auditor will run a report of all subcontract expenditures on federal and federal pass-through projects. The expenditures are matched to corresponding subawards of high-risk subrecipients to determine the sample of invoices for review.
Additional resources for subrecipient monitoring
(Subrecipient Invoice Review Guide & Subrecipient Invoice Checklist Accessible 02/18/19)
Who to contact
IU Grants Finance and Operations, 812-855-0516