PIs have primary responsibility for monitoring subrecipients to ensure compliance with federal regulations and both prime and subrecipient award terms and conditions.
Departmental business managers have responsibility for assisting PIs in discharging their monitoring responsibilities, for reviewing invoices from subrecipients and questioning expenditures if necessary, and for maintaining documentation of monitoring efforts.
RSP has responsibility for ensuring that the university's subrecipient monitoring procedures are compliant with federal and other applicable regulations and are consistent with sound business practices. RSP will provide further training, monitoring and guidance in interpreting applicable regulations and subrecipient award terms and conditions, and in interpreting and executing these guidelines. Additionally, RSP will conduct web site reviews of any subrecipient published UGC to ensure they are conducted and request copies whenever electronic versions are not available as indicated in the contract document through the Federal Audit Clearinghouse web site.
In order to meet requirements for UGC compliance, the university must meet the requirements regarding subrecipients’ performance and compliance under any prime awards or contracts for which it is the fiscal agent of record. To accomplish this requirement, the operating procedures above have been developed to provide an overview of the requirements, workflow, and responsibilities. RSP assists and collaborates with the PI(s) to perform contracting and financial monitoring. The PI is the primary responsible party for ensuring that sponsored research funds (including subrecipient payments and deliverables) are used as awarded from the sponsor and that costs incurred are “allowable, reasonable, and allocable” and that required reporting is accomplished as outlined in the prime award document.