Post-Award Administration

Guidelines for Subrecipient Monitoring by P.I.s

Background

Whenever UCR subawards to another entity, the University must monitor the subrecipient to ensure its compliance with federal laws and regulations. As part of a monitoring program, UC Riverside relies on Principal Investigators and departmental staff to review and determine the allowability, allocability and reasonableness of subrecipient project expenses. Although Principal Investigators have primary responsibility for monitoring the technical progress and claimed costs of subrecipients, it is understood that some of this responsibility is frequently delegated to departmental staff or administrators. The following guidance is provided to assist Principal Investigators and those to whom they have delegated this responsibility.

Definitions

Subrecipient is a legal entity that receives Federal assistance via a subaward from UCR to carry out or administer a program, including responsibility for programmatic decision making.

Subaward is defined, for the purpose of this guidance, as the legal agreement between UCR and a subrecipient that transfers a substantive portion of the scope of work and federal financial assistance funding under an award received by UCR. A subaward does not involve the procurement of goods or non-research services.

Monitoring Guidelines

Below are general guidelines for monitoring subrecipients. If there are specific concerns or questions please contact the Office of Research Contract and Grant Officer assigned to your unit for more detailed advice.

1. Periodic progress reports should be reviewed, comparing results delivered against the subrecipient's statement of work. In addition, the reports should be compared to invoices to determine that the expenses match the progress of the project. Examples of instances that could raise concerns include, but are not limited to:
• A subrecipient consistently invoices UCR for one twelfth of the subaward budget each month; however, the progress reports do not match the level of expense being reported.
• A subrecipient is performing work as evidenced by its progress reports, but has not submitted any invoices or has not submitted invoice in accordance with the terms of the subaward.
2. Subrecipient invoices should be reviewed for allowability, allocability and reasonableness of costs and should be in enough detail to determine how the funds were utilized.
3. Costs which differ materially from the subrecipient's approved budget, or appear unusual or unallowable should be questioned. In addition, payment should be withheld until a satisfactory explanation is received or an appropriate audit/review is performed and the findings of such audit/review resolved or corrected. Examples of when an invoice should be questioned include, but are not limited to:
• A subrecipient's invoice indicates the purchase of equipment, but equipment expenses are not in the approved budget.
• A subrecipient's invoice lists only the total costs claimed without providing any categorical breakdown/detail.
4. Approval of subrecipient invoices should be in writing on the invoice by the Principal Investigator and any supporting documentation should be retained.
5. Final invoices should be identified as such and should not be approved for payment until all deliverables have been received.
6. The Principal Investigator or department staff should promptly contact the Office of Research with any concerns about a subrecipient. Examples of situations that may require further inquiry by the Office of Research include, but are not limited to:
• Suspicion of subrecipient non performance, (e.g. late progress reports).
• Fraud or non-compliance with Federal regulations and laws.
• Any indication that the subrecipient is not fulfilling its obligations under the subaward.