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University of Colorado Denver | Anschutz Medical Campus

University of Colorado Denver
 

Financial Compliance and Training

Tools and Resources: Spotlight On ...


 
 

Subrecipient Monitoring

 

Requirements

The University as the prime award recipient is responsible for identifying the award and flowing down the terms and conditions of the award to all sub-recipients of the award. Principal Investigators and project personnel are responsible for ensuring sub-recipients are complying with University and all federal/sponsor flow through regulations – financially and programmatically.

 

Potential Audit Findings

·         Sub-recipient’s billing did not match the programmatic accomplishments.

·         Sub-recipient charged unallowable expenses.

·         Sub-recipient did not bill for actual expenses.

·         Salaries charged do not match the effort provided by the sub-recipient.

·         Sub-recipient’s billing was untimely and inaccurate.

·         Sub-recipient did not provide or track the mandatory cost sharing commitments. 

 

Methods for Managing Risk

·         Refer to the appropriate policies and procedures and ensure that project personnel involved in monitoring sub-recipients’ performance are familiar with the policy.

o   Campus Policy – Sub-recipient Monitoring

·         Obtain detailed budget and budget narrative from each sub-recipient at the proposal stage along with the scope of work.

·         Require sub-recipients to send detailed financial statements with each invoice allowing you to review detailed transactions to ensure allowability.

·         Use the Sub-recipient Monitoring Invoice Review Checklist.

·         Do not approve invoices for payment if there are any outstanding questions on the programmatic or financial performance. University has the right for additional information before invoice is paid.

 

 

Supplements

 

Article:Education Dean's Fraud Case Teaches U. of Louisville a Hard Lessonby David Glenn, The Chronicles of Higher Education, June 12, 2009

 

OIG Audit Report:Review of Subaward Costs Claimed Under University Of Massachusetts Medical School Prime NIH Grant Number 5 P01 HL56920-05 From February 1, 2001, Through August 31, 2002 (April 7, 2006)” by the Office of Inspector General, Department of Health & Human Services

 

OIG Audit Report:Review of Subaward Costs Claimed by Yale University on NIH Grant Number 5 P01 HL56920-05 From February 1, 2001, Through August 31, 2002 (February 3, 2006) by the Office of Inspector General, Department of Health & Human Services

 

OIG Audit Report:Review of Subaward Costs Claimed by Roger Williams Hospital on NIH Grant Number 5 P01 HL56920-05 From February 1, 2001, Through August 31, 2002 (February 27, 2006) by the Office of Inspector General, Department of Health & Human Services

 

OIG Audit Report:Review of Subaward Costs Claimed by Boston University on NIH Grant Number 5 U01 HL066582-04 and 3 U01 HL066582-04S1 From August 1, 2003, Through July 31, 2005 (September 28, 2006) by the Office of Inspector General, Department of Health & Human Services

 

OIG Audit Report:Review of Costs Claimed By Dartmouth College for NIH Grant No. 5 P01 GM51630-06, May 1, 1998 - December 31, 2002 (September 29, 2005) by the Office of Inspector General, Department of Health & Human Services

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