Subrecipient Monitoring

UMB relies on Principal Investigators (PIs) to be the primary control point to ensure subrecipient work progresses per the agreement. The administrator, program manager, or Principal Investigator reviews periodic reports of technical and programmatic activities, and reviews subrecipient invoices for allocability, allowability, and reasonableness of costs.

Subaward initiation

The Subaward Request collects the documents, data and electronic signature of the PI to approve the initiation of the Subaward. 

Before submitting the request:  

Check again to ensure your Subrecipient’s relationship to UMB is truly that of a Subrecipient, and not that of a supplier/vendor. Review the Vendor or Subrecipient guidance.

Review the subrecipient's statement of work (sometimes called Scope of Work - abbreviated SOW) and obtain an updated version if needed. The SOW includes a clear description of the work the subrecipient will perform, including proposed timelines and deliverables, if applicable. The SOW should clearly demonstrate that the subrecipient has a collaborative relationship with UMB, involving programmatic decision making. Statement of Work template

Review the subrecipient's budget and obtain an updated version if needed. The budget should include detailed cost categories sufficient to satisfy the sponsor’s requirements as well as UMB's needs for expenditure monitoring. Budget template-subaward request

The Subrecipient Commitment Form must be current, completed and signed, for all new subawards and modification requests. Subrecipient Commitment Form

Review the subaward document

The subaward contains:

  • The subaward agreement itself, containing the terms and conditions with which the Subrecipient must comply;
  • The Subrecipient’s Statement of Work, which determines the work the Subrecipient has agreed to do;
  • The Subrecipient’s budget information, which determines how the Subrecipient is allowed to expend funds;
  • The Prime Award, containing the Sponsor’s terms and conditions with which both UMB and the Subrecipient must comply;
  • Other documents (e.g., invoicing or reporting templates, multi-PI leadership plans, data-sharing plans) that pertain to requirements in the subaward.

Maintain an active collaboration with the Subrecipient PI

Subrecipients are partners in UMB’s project work, so it is important to establish good communication from the beginning. The UMB and Subrecipient PIs should communicate regularly about project progress. Keep records of telephone calls, meetings, emails, reports, deliverables, and compliance requirements.

Questions to ask continuously during the life of a subaward include:

  • Is Subrecipient’s work progressing according to schedule?
  • Is the Subrecipient PI alerting UMB to any logistical problems, in a timely manner?
  • Is the Subrecipient PI responsive to communications from UMB?
  • Are the Subrecipient’s compliance requirements up to date? (e.g., Is the Subrecipient providing documentation related to sponsor-specific or program-specific requirements and assurances, such as trainings or approvals for animal use or human subjects?)
  • Is the Subrecipient PI planning to change institutions in the future?

Monitor the Subrecipient’s technical performance

The subrecipient’s Statement of Work is the yardstick against which you will measure the Subrecipient’s technical performance.

Most subawards include technical reporting requirements. Often these are for annual and final reports, or for deliverables/milestones to be accomplished by set due dates. The Subrecipient’s reporting informs UMB’s reporting to the sponsor.

The Subrecipient should always direct their reporting to the UMB PI, who must review it to check for satisfactory progress. Questions to ask when reviewing a Subrecipient’s technical performance include:

  • Is the Subrecipient sticking to their Statement of Work?
  • Are deliverables/reports being provided according to the required due dates?
  • Is the content and form of the deliverables/reports satisfactory?
  • Is the Subrecipient reporting to UMB in a way that easily enables us to complete our reporting to the sponsor?

Monitor the Subrecipient’s spending

Subaward monitoring also includes keeping track of costs that Subrecipient is invoicing for, compared to the approved budget. Invoicing should be compared to the subaward budget, to ensure that the Subrecipient’s spending is what you expected.

A Subrecipient’s spending must be:

  • No greater than the total funds obligated, to date;
  • In general accordance with the approved budget; and
  • Incurred only during the authorized performance period.

Subawards always include invoicing requirements. Subaward terms usually request monthly invoicing.

The Subrecipient’s invoicing is tied to UMB’s invoicing of the sponsor. The Subrecipients are usually required to submit detailed line-item invoices.

It is the responsibility of the UMB PI or their delegate to ensure that expenses included on the invoice conform with the work performed by the Subrecipient. The UMB PI should always be involved in reviewing and approving invoice, and should only approve invoices that provide detail sufficient to show that expenditures are allowable, allocable, and reasonable. Invoices that don’t meet this requirement should be returned to the Subrecipient for correction or clarification. Work with Accounts Payable regarding any invoice issues.

Questions to ask when reviewing a Subrecipient’s invoices include:

  • Do the invoices provide enough detail to show how the funds were expended?
  • Do invoices reflect allowable, allocable, and reasonable costs?
  • Is the Subrecipient spending funds according to the budget and project time lines?
  • Is effort charged reasonable for the progress made?
  • Has the Subrecipient PI (and other Senior/Key Persons) met their effort commitment? (if applicable)
  • Is the Subrecipient verifying committed cost sharing? (if applicable)
  • Is the Subrecipient providing carryover requests? (if applicable)

Know when it’s time to modify a subaward

Most subawards will need to be modified (amended) during their lifetime. Understanding when modifications are usually needed will help you request them in time to avoid work delays caused by late modifications. The Subrecipient Commitment Form is needed for each modification request to assess the risk of the organization and project. 

Typical modifications are:

Continuation:  annual funding increment and budget period extension

Increment:  add funding without changing the budget period

No-cost extension:  extend the budget period without adding more funding

Change of subrecipient PI:  usually requires sponsor approval

Change of subrecipient institution:  involves terminating the existing subaward and issuing a new one to the new institution. May require sponsor approval

Carry-forward: Modifications to approve the Subrecipient’s carry-forward are only needed if the subaward terms require it. Generally speaking, if a Prime Award allows UMB to carry forward unspent funds to the next budget period without sponsor approval, the Subrecipient will be allowed to carry forward unspent funds without UMB approval (unless the UMB PI has asked to approve carry-forward). If the Prime Award requires sponsor approval of carry-forward, the request for sponsor approval should address carry-forward for the Subrecipient, as appropriate for the project.

Alert SPA of problems with the Subrecipient

If you see that a Subrecipient is not complying with the terms of their subaward, spending funds as expected, performing work as expected, or submitting required reports or deliverables, communicate this right away to the Subrecipient’s PI. Addressing problems or misunderstandings early on, helps avoid larger problems later.

If the Subrecipient is not responsive in addressing problems or deficiencies, notify Accounts Payable and your SPA Team to delay future payments until the issue is resolved. Document the issue and related communications with the Subrecipient. SPA will attempt to amicably resolve the problems, before taking any stricter measures.