Contracts and Grants Policy 13 – Sub-Recipient/Sub-Award Monitoring

Federal funding agencies require that institutions working on subawards under UNCG prime awards follow all of the rules and regulations that would apply if the award had been issued to them directly.  As a prime recipient and a pass through entity of Federal awards, UNCG is responsible for monitoring the programmatic and financial activities of its subrecipients in order to ensure proper stewardship of sponsor funds.   The UNCG subrecipient monitoring policy provides guidelines for this process.

This guidance will address institutional responsibilities and assist 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. The Office of Contracts and Grants (CGS) may impose specific controls, as needed, for certain Subrecipients based on relevant risk factors.

OMB Guidance

OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR §200) (“Uniform Guidance”), specifically sections §200.330 and §200.331, requires prime recipients of federal funds to monitor sub-awards and to ensure subrecipients meet the audit requirements in Subpart F and use funds in accordance with applicable laws, regulations and terms of the award.

Risk Assessment

Prior to issuance of the sub-award, The Office of Sponsored Programs collects the Subagreement Assurances Form data that certifies the rates, cost sharing, IRB/IACUC, COI, and fiscal responsibility of the subreceipient.  In addition, The Office of Contracts & Grants (CGS) completes a Risk Assessment to determine the appropriate level of monitoring and ensure monitoring and reporting requirements are incorporated into the sub-award document as needed.

Monitoring

UNCG will utilize two kinds of monitoring: (1) CGS performs cost review of invoices and making sure that the subrecipient institution complies with the auditing requirements of the OMB Circular’s, and (2) the PI making sure that the subrecipient unit at that institution is managing the subaward correctly.

PI / Department Administrator Responsibility:

The Principal Investigator (PI) is responsible for monitoring the activities of the sub-recipient, and confirms that costs are appropriate and reported timely relative to the programmatic activity of the scope of work. The sub-recipient should submit progress reports, technical reports and other deliverables to the PI by specified due dates.

Post Award Sub-Recipient Monitoring Procedures

CGS will review the sub-recipient’s invoice(s) for the following:

Period of performance is within the contract period

Appropriate invoice format and level of detail

Signatures of the PI

Funds are available in contract

Cost Share documentation, if applicable

Related Forms

PI Invoice Approval Certification (CGBANFIN-32)

Risk Assessment

Invoice Review Guidelines