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Upon completion of a fully-executed subaward, the business/finance office and principal investigator should begin to fulfill the roles and responsibilities of managing and monitoring the subaward.
Based on the compliance review at the subaward initiation phase, the Office of Research Contracts (ORC) established a risk level for the subaward. The Subrecipient Monitoring Guide includes a risk assessment level matrix. The matrix describes the subrecipient monitoring actions required at each risk level by the principal investigator and the business/finance office for the subaward. An example of the Subrecipient Monitoring Responsibilities Acknowledgement Form is available under Forms & Templates.
Subrecipient monitoring activities by the principal investigator and business/finance office according to the assigned risk level include:
- Implementing the communication schedule established in the subaward
- Monitoring progress of the subaward
- Reviewing invoices and financial reports for irregularities, lack of progress, and improper cost accounting
- Sample review of cost items by the business/finance office on a regular basis
- Invoices, annual and final financial reports MUST include the invoice certification requirement from OMB Uniform Guidance for any new prime award funds received
- Review performance/progress report as determined by risk level
- Site visits to the subrecipient by the principal investigator
- Periodic desk audit by the business/finance office and/or Subawards
Subrecipient monitoring by the principal investigator and business/finance office also includes keeping a copy of the following:
- Budget Negotiation Documentation form – including copy of rate agreement and other documentation to support costs associated with the budget
- Each invoice should have the required system-generated financial report and Payment Authorization Form
- All reports – technical, progress/performance, financial, annual, etc.
- Financial report submitted with invoice should include transactional and payroll records
- Annual financial report should be a summary, by cost categories, of expenses incurred during the prior year, as well as a cumulative total
- Final financial report submitted with the final invoice should be a summary, by cost categories, of the total expenses for the ENTIRE Subaward
- Performance/progress reports include verification of the work being conducted and the results are in line with the approved scope of work
- Technical report should be a detailed report of the activities carried out and ALL deliverables associated with the approved scope of work
- All other documentation serving as the proof of subrecipient monitoring activities. For example, meeting agenda and notes, etc.
Subrecipient payment approval process is an opportunity for the principal investigator and business/finance office to review an invoice and supporting financial report for allowability and reasonability of costs. The Subrecipient Monitoring Guide provides detailed guidance on invoice review. Once the invoice is reviewed and approved, the principal investigator and business/finance office will complete the Subaward Payment Authorization Form and submit it together with the subrecipient’s invoice to Accounts Payable (AP) for payment. The Sponsored Projects Financial Compliance team reviews/approves UAccess Financials Payment Request initiated by AP and approved by the business/finance office.
The invoice certification requirement from the OMB Uniform Guidance (2 CFR 200), Section 200.415 is required on all invoices, annual and final financial reports for any new prime award funds. The Subawards Team has incorporated the following required language into terms of the new and existing subawards:
“By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (U.S. code Title 18, Section 1001 and Title 31, Sections 3729-3730 and 3801-3812).”
When necessary, the principal investigator and business/finance office will request a subaward modification by completing and submitting the Subaward Initiation Smartsheet (SIS). Please do NOT initiate a Purchase Order Amendment (POA) until notified by ORC. A POA in UAccess Financial will prevent invoice payments from being processed.
A modification is generally required for these changes:
- Add additional funding
- Extend the subaward end date
- Modify or add terms and conditions
- Change of prime award PI or subrecipient PI
- Change of scope of work or budget
Upon receipt of the initiation form, ORC begins the various required compliance checks:
- Financial audit checks based on OMB Uniform Guidance under 2 CFR 200, Subpart F
- Compliance requirement checks (Export Control, Conflict of Interest, SAM.gov registration, etc.)
- Compliance check for debarred/suspended entities and individuals as stipulated in the Subrecipient Monitoring Guide
- Complete risk assessment of subrecipient to establish risk level. Each risk level conveys a different set of responsibilities for the principal investigator and business/finance office as defined in the Subrecipient Monitoring Guide
Note: Per OMB Uniform Guidance, compliance checks must be performed on an annual basis.
After compliance checks, ORC will draft the modification and forward the draft to the the principal investigator and business/finance office for approval. If approved, ORC then sends it to the subrecipient for review and signature. Additional negotiation of the subaward terms may be necessary and require further principal investigator and business/finance office involvement. Upon final agreement between the University of Arizona and the subrecipient, ORC will obtain a partially signed modification from the subrecipient.
Once a partially signed modification has been obtained, ORC will direct the business/finance office to initiate the UAccess Financials Purchase Order Amendment (POA). For more information about amending a purchase order for a subaward, navigate to the UPK training provided by University Information Technology Services (UITS). Enter "subcontract" in the search box and select "Amending a Purchase Order for a Subcontract."
Not all subaward modifications require a POA via UAccess Financial. A POA is required for these actions:
- No cost extension
- Addition or reduction of funds
- Additional funds and extension of time period
- Change in subrecipient legal name
All other changes such as change of scope and budget, change of UA PI, and modify terms and conditions will require the issuance of a legal modification but a POA via UAccess Financial is not required.
When the POA routes to ORC, they will approve, provided the amendment matches the agreement changes. After Procurement & Contracting Services (PACS) finalizes the POA, ORC will countersign the subaward modification and provide the fully-executed document to the subrecipient and the University of Arizona business/finance office.