Monitor a Subaward

PI Responsibilities

The Principal Investigator is responsible for monitoring subrecipients so there is reasonable assurance that the subrecipient uses the award for authorized purposes, complies with laws, regulation, and the provisions of the agreement, invoices UCD for allowable expenses in accordance with the agreement, and achieves its performance goals.

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A helpful resource: Learn: Subawards – webpage with FAQs, written materials, how-to videos, and links to eCourses and instructor-led trainings

Review the subrecipient’s invoices

Indicate approval by personally signing each invoice for payment, after full review and concluding that all charges are appropriately made/invoiced.

As part of invoice review, the PI (typically with assistance from the departmental administrators, although PI is fully responsible for the entire process) is responsible for verifying that the invoice was prepared in accordance with the subaward requirements and that invoiced costs are:

• • Submitted in accordance with the required invoice frequency
  • Are submitted using any required invoice template
  • In accordance with the approved budget or permissible rebudgeting and reflects the appropriate F&A rate
  • Incurred within the approved period of performance and overall cost limitations
  • Aligned in terms of cost and type of expense with the scientific progress reported to date
  • Allowable, allocable, and reasonable

Subrecipients must submit a final invoice, clearly marked “Final”, to UC Davis by the date that is required in the subaward agreement, typically no later than 60 days after the end of the subrecipient’s period of performance.

Clarify invoiced charges

Request additional documentation as may be necessary if the level of detail included on an invoice is not sufficient to fully understand the costs, or if it appears that some costs may be excessive or understated.

Such inquiries must be done in a timely manner (e.g., within thirty days after receipt of an invoice) so that the subrecipient can be promptly paid for approved costs.

Examples of detailed justifications that may be requested from subrecipients include:

• • Payroll records
  • Copies of paid invoices showing the cost of items purchased
  • Descriptions of services rendered by consultants, including hourly rates and time reports
  • Details of incurred travel charges stating the purpose, airfare, meals, ground transportation, unallowable costs, etc.

Copies of all such documentation and the ultimate outcome of the investigation should be retained in the project file.

Review all progress, technical and financial reports

Ensure they are complete and comply with all requirements stipulated in the subaward, including frequency/timeframe requirements.

Discuss technical progress, financial matters, and compliance with the subrecipient.

The PI is obligated to be in contact with the subrecipient regularly to discuss progress and receive and review required reports or deliverables.

Monitor regulations and assurances

The federal regulations that describe subrecipient monitoring are general, but contain the following core elements of compliance:

• • Advising subrecipients of all applicable federal laws and regulations, and all appropriate flow-down provisions from the prime agreement
  • The routine receipt and review of technical performance reports
  • The routine review of expenses-to-budget
  • The periodic performance of on-site visits, or regular contact, if necessary
  • The option to perform “audits” if necessary, review of audit reports filed by subrecipients, and any audit findings review of corrective actions cited by subrecipients in response to their audit findings
  • Consideration of sanctions on subrecipients in cases of continued inability or unwillingness to have required audits or to correct non-compliant actions
  • In addition to the general elements of compliance noted above, there may be additional sponsor- or program-specific requirements that mandate collecting and documenting other assurances (e.g., on lab animals, human subjects, biohazards, etc.) during the course of a project.

Keep detailed documentation of unsatisfactory performance by the subrecipient.

Retain all invoices and reports in the department’s files for audit purposes.

For International Subrecipients to an NIH Grant and Where UC Davis is the Primary Funding Recipient Only:

Effective January 1, 2024, PI ensures subrecipient access (electronic access permissible) to copies of all lab notebooks, all data, and all documentation associated with the research as described in the progress report to the primary funding recipient and in alignment with progress report submission requirements, but on no less than an annual basis per NIH GPS 15.2.1.

• • PI should verify access and document the location of materials provided by the subrecipient, retaining documentation and access location for a period of three (3) years from the date of submission of the grant’s final financial report.

Other subaward stages

• • Outgoing Subawards – Overview of all subaward stages
  • Prepare a proposal with subawards – If a proposal is to include a subaward to a subrecipient (or subawards to subrecipients), the information indicated on this page should be included in the proposal.
  • Send a subaward request to SPO – Once a Prime Award has been awarded (fully executed) to UC Davis, the PI must send a request to the Sponsored Programs Office (SPO) that the subaward(s) be sent to the subrecipient(s).
  • Closeout a Subaward – Once a project with a subaward is complete, it must be closed out.