Monitoring Performance During the Life of the Subaward
Principal Investigators have the primary responsibility for monitoring subrecipients to ensure the responsible stewardship of funds and performance of the work, including:
- Authorizing the Subaward, including funding level, period of performance and scope of work
- Certifying that work performed by the subrecipient is complete and acceptable.
- Standard language: "To the best of my knowledge, I certify that the subawardee's invoice costs appear reasonable and fairly correlate with the technical progress made on this research project."
- Maintaining regular contact with the subrecipient PI regarding all technical aspects of the project
- Ensuring all deliverables required under the subaward agreement are being completed and provided
- Reviewing and approving subrecipient invoices in a timely manner
- Communicating problems with reporting or deliverables to the local business office and OSP
Department, lab and center administrators are responsible for assisting PIs in carrying out their subrecipient monitoring responsibilities, Including:
- Providing up to date scope of work, budget and other supporting information to OSP, as needed
- Ensuring that invoices are approved by the PI or his/her designee and returned to OSP in a timely manner
- Requesting clarification from the subrecipient regarding any unusual or excessive charges invoiced by the subrecipient
- Where the PI has not approved the invoice directly, maintaining copies of all documents that provide evidence of the regular review of invoices by the PI
- “Evidence” can be in the form of an authorized signature on an invoice by the PI or his/her designee, PI’s initials, e-mail communications, or notes of meeting between the PI with the department administrator.
- Maintaining documentation of monitoring efforts (copies of e-mails, phone log, etc.)
Receiving and Approving Invoices
Subrecipients are instructed to submit their invoices to the OSP Subawards Team. It is the goal of the OSP Subawards Team to pay invoices efficiently and in compliance with our subrecipient monitoring program.
Click on image to see a larger version.
OSP Subawards Team reviews all subrecipient invoices to ensure that they meet the following standards prior to sending them to the PI and DLC for approval:
- Invoiced amounts are within the obligated and available funds limits and within the approved period of performance
- Cost share is included on invoice if required under the subaward
- F&A rates are being charged appropriately
- Invoiced amount is allocated to over/under $25K
- Special processing terms and conditions are highlighted for PI/DLC review. For example:
- Time & Materials rates are appropriate for T&M subawards
- For federal contracts, spending is reviewed against sponsor-approved budget
- Equipment is not being charged where equipment costs are unallowable
After reviewing the invoice, the Sub Team stamps the invoice and forwards it to the DLC Administrator.
PI, assisted by DLC Administrator
- Certifies that the work performed by the subrecipient is being completed and is acceptable
- Reviews the invoices or expenditures and ensures costs are appropriate for the work performed
- Ensures that the actual cost share committment has been met and the subrecipient has provided sufficient documentation and substanciation of the committment
- Reviews invoices for compliance with a subrecipient monitoring Management Plan (for high-risk subrecipients only)
- If the PI is not directly approving the invoice, the DLC Administrator maintains documentation of the PIs approval
After signing off on an invoice, the DLC Administrator scans and sends the approved invoice back to the OSP Subawards Team who will mark the final approval and forward the invoice for payment to Accounts Payable.