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 Lesson” by 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