Subrecipient Monitoring

Subrecipient Management and Monitoring

Risk Assessment & Ongoing Monitoring 

Under §200.331, all pass-through entities (PTEs) are required to evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and associated award terms and conditions. 

Dartmouth employs a risk-based approach to subrecipient monitoring, focusing more robust monitoring efforts on subrecipients deemed to pose an elevated risk for potential non-compliance. 

Prior to proposal submission the Pre-Award team verifies compliance of financial conflict of interest following institutional policy and applicable regulations. Once awarded, the Pre-Award team reviews the Notice of Award. If applicable, the IRB and IACUC protocols are verified. The Sponsored Research Manager (SRM) of the prime award reviews the Notice of Award to confirm issuance of a subaward agreement. SRM sets up a subaward agreement for each subrecipient referenced in the proposal/notice of award. A risk assessment is performed by Sponsored Research Manager for each new subaward agreement. The risk assessment verifies the subrecipient is not or has not been suspended or debarred, by searching System of Award Management and Visual Compliance, and includes review of internal controls the subrecipient has in place. A form evaluating risk is saved to the subaward record in RAPPORT. 

If additional monitoring is necessary specific conditions under §200.208 can be utilized. Examples of additional monitoring conditions that can be incorporated into subaward 

• Require that costs are supported by adequate documentation such as detailed transaction reports, vendor invoices, canceled checks, time and attendance records, approved purchase orders, receiving documents 
• Issue fixed price agreements (§200.332) based on milestone/deliverable completion of certain tasks 
• Schedule site visits to review records and observe operations 
• Arrange for limited-scope audits of certain activities 
• Require third-party evaluations 
• Require a technical report to accompany invoices 
• Establishing additional prior approvals 
• Provide technical assistance and training 
• Add more stringent termination or stop-work language for failure to comply with requirements 

Ongoing monitoring includes, invoicing and scientific progress as well as annual reassessment of risk resulting from annual single audits. 

Invoices from the subrecipients are submitted to OSP via email or electronic system (OnBase) for initial review of financial aspects on the invoices. 

When OSP receives a subaward invoice, the following items are verified: 

• Executed Agreement 
• Logistical Information 
• Invoices are within the budget period.
• Expenses on invoices are within the awarded budget.
• Certification Statement is included and accurate.

If any of the above criteria is not met, OSP contacts the subrecipient requesting additional documentation or that the subrecipient submits a revised invoice.

After the review is complete OSP inputs data from the invoice into OnBase and routes to the DGM and PI for review and approval. The DGM and PI review invoices to ensure that expense categories are appropriate and in compliance with sponsor guidelines. They review the following: 

• Appropriateness of costs. (PI and DGM)
• Progress of Work being Completed. (PI)
• Invoices are within the budget period. (PI and DGM)
• Expenses on invoices are within the awarded budget. (PI and DGM)
• If there is required cost sharing, determining the subrecipient's cost share is within expectations. (PI and DGM)

If there are issues with costs or work progress, the DGM or PI will not approve the invoice and will notify OSP about these issues so that OSP can work towards resolving these issues. The original invoice is put on hold in OnBase until issues are resolved. If necessary, a revised invoice will be requested from the subrecipient by OSP.

If the invoice is compliant (by meeting the above requiements) and all approvals are met, the invoice is automatically routed to the appropriate Finance Center for processing. Payment is made in accordance with §200.305(a)(3). 

Invoice desk reviews are utilized for ongoing monitoring. OSP may periodically select subrecipient invoices for desk audit. Invoice supporting documentation is requested from selected subrecipients and reviewed to determine invoice accuracy and accountability. When supporting documentation is received by OSP (DGM and PI as necessary) they verify expenditures are supported and in alignment with subrecipient agreement or amendment. 

Annually OSP collects and reviews subrecipient single audits in accordance with §20.501.

OSP tracks collection of Single Audit reports using an excel spreadsheet. The spreadsheet is an output of a systematic internal report identifying subrecipient expenditures and includes subrecipient name, if single audit has been received, findings, follow-up if applicable, contact information, etc.

OSP reviews the subrecipient's Single Audit from the FDP Expanded Clearinghouse and the Federal Audit Clearinghouse. This web site provides evidence verifying subrecipients have completed a Single Audit, indicated any audit findings, and determined audits were performed within the Federal deadlines. OSP also searches the separate institutional websites if more comprehensive information is needed. 

Each report is reviewed for findings related specifically to funds issued by Dartmouth. If there are findings relating to funds from Dartmouth; OSP will request more information, investigate the findings, follow up with the subrecipient to rectify the problem, and maintain information on a spreadsheet. If there are no findings, notation is made on the spreadsheet. 

Per Uniform Guidance §200.331(d)(3), OSP will issue a management decision letter to subrecipient(s) with audit findings pertaining to funds from the subaward issued by Dartmouth within six months of acceptance of the subrecipient audit report by the Federal Audit Clearinghouse. OSP will request additional information regarding corrective action specific to the finding(s). Corrective actions cited by the subrecipient are reviewed to ensure the subrecipient is compliant and determine if additional monitoring will be required. 

When subrecipients are not subject to Single Audit (including foreign and for-profit entities), the College establishes its own requirements, as necessary, to ensure compliance. OSP requests a certification statement to confirm there were no findings with funds passed through to the entity from Dartmouth. 

At award closeout activities related to ensuring that the work was performed and properly billed are finalized. At the end of the award, the DGM and PI are responsible for ensuring that all documentation related to project performance and financial obligations are received. Subrecipient monitoring activities that should be performed at award closeout include: 

• Verify that the final invoice is received and marked “final”. 

Subcontracting Guide and Resources including Matrix & Checklist