Sub-Recipient and Sub-Award Monitoring Policy

Clark University researchers often collaborate on funded projects with colleagues at other institutions, contractors providing services, and other organizations. If Clark University is the prime recipient and a pass-through entity of funded awards with sub-awards, the University follows established policies and procedures.

As a prime recipient and a pass through entity of Federal awards, Clark University is required to monitor the activities of sub-recipients. In order meet the requirements of the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements For Federal Awards (2 CFR 200), commonly known as Uniform Guidance, the University shall perform the following with respect to sub-recipients/sub-awards:

Identify Federal awards made by informing each sub-recipient of CFDA title and number, award name and number, award year, if the award is R&D, and name of Federal agency. If any of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award.
Advise sub-recipient of requirements imposed on them by Federal laws, regulations, and the provisions of contracts or grant agreements as well as any supplemental requirements imposed by the pass-through entity.
Monitor the activities of sub-recipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grants agreements and that the performance goals are achieved.
Ensure that sub-recipients expending $750,000 or more in Federal awards during the sub-recipient’s fiscal year have met the audit requirements of 2 CFR 200 for that fiscal year.
Issue a management decision on audit findings within six months after receipt of the sub-recipient’s audit report and ensure that the sub-recipient takes appropriate and timely corrective action.
Consider whether sub-recipient audits necessitate adjustment of the pass-through entity’s own records.
Require each sub-recipient to permit the pass-through entity and auditors to have access to the records and financial statements as necessary for the pass-through entity to comply with this part.

The Principal Investigator (PI) is responsible for monitoring the activities of the sub-recipient to ensure compliance with the progression of work, progress reports, technical reports and other deliverables by specified due dates. Any concerns or issues related to sub-award or sub-recipient monitoring should be brought to the attention of OSPR. PI, or assigned designee, is responsible for forwarding copies of the sub-recipient’s progress report and/or technical report(s) to OSPR.

Sub-recipient Invoices
Grant Accounting Review
Closeout Requirements

Sub-recipient invoices submitted to the University must contain the following information:

Invoice must be on the sub-recipient’s letterhead
Date of invoice
Invoice number
Period of performance covered by the invoice
Itemized description of services and backup documentation
Current period costs, including cost sharing
Cumulative projects costs, including cost sharing
Sub-recipient contact person with respect to invoice
Invoice must be signed by an authorized official of the sub-recipient
Invoice must contain a certification that all payments requested are for appropriate purposes and in accordance with the agreements set forth in the application and award documents

The PI is also responsible for reviewing and approving invoices from sub-recipient(s) for adherence to the budget. The signature of the PI, or assigned designee, on the invoice indicates that the review has taken place and that the invoice adheres to the budget.

Grants Accounting will review the sub-recipient’s invoice(s) for the following:

Period of performance is within the contract period
Appropriate invoice format and level of detail
Signatures of the PI, or assigned designee
Certification or signature by authorized sub-recipient representatives
Funds are available in contract
Cost Share documentation, if applicable

Grants Accounting is responsible for ensuring that sub-recipients that expend $750,000 or more of federal funds each fiscal year submit an Audit Certification Letter.

Sub-recipient award closeout requirements:

Annual Audit certification letter

Receipt of final invoice

Receipt of Cost Share documentation, if applicable

Time and Effort certifications

Final progress and technical reports

Contact Information

Sub-Recipient and Sub-Award Monitoring

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