1307 PR.03 Monitoring Subrecipient Activity Associated with Sponsored Programs
This procedure outlines the process for monitoring subrecipients under a prime award to Yale and supports Policy 1307 Subrecipient – Establishing, Managing, and Monitoring. All faculty and staff involved in the conduct and/or oversight of sponsored research involving a subrecipient are expected to follow the procedures outlined in this document.
Reason for the Procedure
Yale has the responsibility for ensuring that all research carried out by a subrecipient is conducted and administered in compliance with federal regulations, as well as sponsor and Yale requirements. This procedure defines general roles and responsibilities of the affected individuals and describes the activities that should be undertaken when monitoring subrecipients.
Proper monitoring of a subrecipient ensures that awarded funds are used for authorized purposes only and that the subrecipient is in compliance with the provisions of the subaward. Monitoring is multi-faceted and requires the participation of the Principal Investigator (PI), Department Business Office (DBO), and Office of Sponsored Projects (OSP) to ensure funds are appropriately spent and performance goals are achieved.
A. Department Business Office (DBO) – Subrecipient Monitoring Activities
DBOs should utilize the following Workday reports to monitor subrecipient activity:
Find Subawards – Yale Report – Generate this report on a monthly basis to monitor and ensure the accuracy of subaward balances.
Subaward Invoices in Progress – Yale – Generate this report on a bi-weekly basis in order to review subaward invoices not yet paid. To view subrecipient invoices, use the “Supplier Group” prompt and choose “Sponsored Sub Award Group.” This report provides the number of days or aging of an invoice based on when the invoice was created in Workday. The invoice age within the report assists DBOs to ensure that subrecipient invoices issued under a federal prime award are paid within the required 30 days of receipt. DBOs can also drill down on the Supplier Invoice Document within the report in order to review the Process History tab. The Process History information includes the status of invoices and provides relevant information in order to address any payment issues.
B. Monitoring of Scientific Progress, Technical Reports, and Deliverables by the Principal Investigator
A PI’s responsibilities related to the monitoring of the subrecipient include, but may not be limited to:
- Reviewing financial and programmatic reports;
- Ensuring that the subrecipient PI fulfills his/her reporting/deliverables requirements, which may include on-site reviews, regular skype, telephone conferences, etc.; and
- Ensuring that all required performance/technical/progress reports and other deliverables required by the subaward are retained in accordance with record retention requirements (Policy 1105 Retention of University Financial Records) and for future audit purposes.
PIs are responsible for monitoring the progress of a subrecipient’s performance in accordance with the subaward’s scope of work. Performance monitoring is an ongoing activity and, depending on the research activity and type of award, at a minimum, the PI should connect with his/her counterpart at the subrecipient organization at least quarterly, if not more frequently.
In monitoring the performance of the subrecipient, the PI may receive informal progress reports in telephone conversations, e-mail communications, face-to-face discussions, or formal technical reports, depending on the terms of the subaward. In the event that a subrecipient fails to perform the subaward’s scope of work or comply with the terms and conditions, the PI must immediately notify OSP for further instruction.
When a subrecipient does not meet or cannot meet the terms and conditions of the subaward, or Yale’s PI is not satisfied with the progress of the subrecipient’s work, the PI, DBO, and OSP Manager must discuss placing additional monitoring and/or reporting requirements for the subrecipient. If the PI and the subrecipient cannot agree to a remedy to bring the subrecipient into compliance with the terms and conditions of the subaward and the completion of the scope of work, the PI has the option of terminating the subaward agreement and should contact the OSP Manager to begin the process of terminating the subaward.
If a PI chooses not to terminate the subaward, additional conditions may be added to the subaward agreement to bring the subrecipient into compliance. For example:
- Requiring additional detailed financial reports/invoices;
- Requiring additional project monitoring;
- Requiring the subrecipient to obtain technical or management assistance;
- Withholding authority to proceed to the next phase of a project until evidence of acceptable performance within a given period of performance is received; and
- Establishing additional prior approvals requirements.
C. Office of Sponsored Projects (OSP) – Subrecipient Monitoring Activities
On a quarterly basis, OSP’s Senior Financial Analyst performs desk reviews of randomly selected subawards. The selection is comprised of foreign and domestic subawards chosen from subrecipient invoices paid during the preceding quarter. The desk review consists of the completion of a questionnaire initiated by the Senior Financial Analyst. The PI and DBO each respond to their respective portions of the questionnaire. The questionnaire covers financial aspects of the subaward, such as the review and approval of invoices and invoice/budgetary compliance. The PI responds to questions relating to the ongoing progress of the SOW, provides his/her opinion of the progress, addresses any problems relating to the science, and responds to questions regarding method and frequency of communication with the subrecipient. The Senior Financial Analyst reviews the invoices processed in the fiscal quarter for budgetary compliance and compliance with regard to proper invoice authorization and documents all findings in the SQ. Results of quarterly desk audits, regardless of the outcome, are distributed to the appropriate stakeholders (e.g., BOLT, FRMS).
On an ongoing basis, OSP monitors a subrecipient’s compliance with the terms and conditions of the subaward. OSP risk assessment activities include but are not limited to:
- Ensuring the timely submissions of performance reports and invoices;
- The review of audit reports and ensuring deficiencies are addressed in a timely manner by the subrecipient; and
- Management decisions for audit findings are provided to the subrecipient in accordance with 2 CFR Part 200 (Uniform Guidance), as appropriate.
If the monitoring activity results in findings, OSP may consult with the PI, DBO, the Office of the Controller, the University Research Compliance Officer, and General Counsel to determine what corrective action should be taken.
All monitoring activities are conducted in accordance with OSP’s Standard Operating Procedure: Determining Risk Level of a Subrecipient and Subsequent Monitoring.
Roles and Responsibilities
Office of Sponsored Projects
- Monitors and provides guidance in interpreting applicable regulations and subrecipient award terms and conditions.
- Determines the ongoing monitoring activities that will be undertaken to ensure subrecipients’ compliance with the terms and conditions of the subaward.
- Conducts periodic reviews of subrecipient compliance.
- Monitors the technical progress of a subrecipient’s performance as defined in the SOW of the subaward.
- Notifies OSP immediately if there is a performance problem with a subrecipient or the need to add/reduce funding, extend the performance period or terminate the subaward.
- Monitors remaining balance of subaward to ensure timeliness of invoice submission by subrecipient.
- Monitors status of invoices to ensure timeliness and accuracy of payments.