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Who monitors subrecipients?
When Indiana University issues a subaward agreement on a sponsored award the department is responsible. Several parties share responsibility for monitoring the agreement: the principal investigator, the fiscal officer or delegate, and IU's Office of Research Administration.
Subrecipient monitoring responsibilities
- 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
- Verify all information on the purchase order, including expense object codes
- 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 codes are used on payments and are allocated properly for the first $25,000 to object code 4074 when appropriate
- Verify the Subrecipient Invoice template (Accessible 08/16/23) was used when the high-risk subrecipient invoiced IU
- Verify the required additional documentation for high-risk subrecipients is acceptable
- Document the principal investigator's approval of the invoice
- Coordinate with the principal investigator and subrecipient to resolve identified issues
- Pending invoices should be placed on hold or canceled
- Retain documentation of invoice review
- The contract officer will review the most recently completed subrecipient risk assessment to determine the risk level of the subrecipient. 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.
Grants, Finance and Operations:
Subrecipients identified as high–risk entities undergo further evaluation. For this activity, Indiana University will select a sample of invoices of high–risk entities and verify that subrecipients are in compliance with Uniform Guidance, which could include verifying:
- The subrecipient used IU's invoice template
- The invoice billing period is at least quarterly
- The invoice includes expense categories, current costs and cumulative costs
- The subrecipient signed the attestation statement
- The exchange rate if applicable, was converted using an exchange rate on the last day of the invoice billing period or an average rate for the invoice period
- The subrecipient provided the required documentation to support the expenditures billed
- The department completed the high-risk subrecipient invoice checklist
Additional resources for subrecipient monitoring