Subrecipient MonitoringAnd Invoice Review

Aimee HowellUMBC

Office of Contract and Grant

Accounting

Tamara LucasUniversity of Maryland

School of MedicineDepartments of Pathology and Medical & Research

Technology

What is subrecipient monitoring?• A process that evaluates how a grantee is

administering a grant according to the requirements of the grant

Why is monitoring important?• Ensures compliance with federal rules and

regulations• Ensures services are provided in accordance

with subaward agreement2

Subrecipient Monitoring

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Proposal Stage Activities• Subrecipient’s – Statement of Work (SOW)– Budget– Budget Justification– Institutional Approval

• Obtain all contact information– Technical, departmental, pre-award, post-award

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Subrecipient Monitoring

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Pre-Award Activities

• Review Prime Award for changes– Impact on subaward

• Communicate with subrecipient PI’s & Dept. Representatives

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Subrecipient Monitoring

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Monitoring activities may take different forms:

• Performance report/technical progress

• Invoice review

• Regular contact

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Technical Progress• Review results delivered against SoW in

subaward• Award modifications occur as needed• Review invoices against technical and

programmatic activities– PI Stamp/Certification

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Monitoring Subrecipient Expenditures

• Invoices are submitted in accordance with subaward requirements

• Invoices only contain expenses that are • Allowable (are there any prior approvals required?)• Allocable• Reasonable

• Verify cost sharing is appropriately reflected if required

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Invoice Review

• Subcontractor invoices should be in enough detail to determine how the funds are being used

• It is the responsibility of the PI or their delegate to ensure the work as indicated on the invoice has been performed in accordance with the terms of the subaward

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Invoice Review• Question costs which differ materially from

the approved budget, or which appear unusual or unallowable

• Withhold payment until a satisfactory explanation or revised invoice is received– Inform pre-award office and subcontractor

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Invoice Checklist• Costs incurred within Period of Performance• Duplicate costs or invoices have not been

submitted• Invoice totals correctly• F&A calculated correctly

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Regular Contact• Maintain regular contact with the subrecipient – Kick-off meeting– Periodic e-mail, conference calls • Weekly, monthly, quarterly

– Site Visits ?

• Document monitoring efforts

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Subrecipient Monitoring

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Subaward Closeout• 60 days prior to end of subrecipient period of

performance begin closeout review– Budgetary actions– Extension requirments

• Verify fulfillment of any cost-sharing requirements

• Verify receipt of invoice marked “Final” • Obtain all final reports (including property

reports) 16

Questions/Comments!

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Aimee Howellahowell@umbc.edu(410) 455-5572

Tamara Lucastlucas@som.umaryland.edu(410) 706-8170

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