Policy
This policy outlines the University of Utah’s requirements and responsibilities for monitoring subrecipients under sponsored awards. It provides guidance to help ensure compliance with federal regulations, protect sponsor funds, and support successful research partnerships.
Policy Statement
The University of Utah is responsible for monitoring the programmatic and financial activities of its subrecipients to ensure proper stewardship of sponsor funds. This policy applies to all subawards issued under sponsored programs awarded to the University of Utah, regardless of the primary source of funding.
This policy defines institutional responsibilities and assists Principal Investigators (PIs) and administrators in ensuring that subrecipients achieve performance goals while complying with federal laws, regulations, and the specific provisions of each subaward agreement.
Reason for Policy
Under the OMB Uniform Guidance (2 CFR §200.332), the University of Utah, as a pass-through entity, is required to:
- Evaluate Risk: Assess each subrecipient's risk of noncompliance to determine appropriate monitoring levels.
- Monitor activities: Ensure subawards are used for authorized purposes in compliance with federal statutes and award terms.
- Verify audits: Confirm that subrecipients are audited as required by Subpart F of the Uniform Guidance.
Failure to adequately monitor subrecipients can lead to financial clawbacks, reputational damage, and may jeopardize the University's ability to secure future external funding.
Who Must Comply
This policy applies to all University of Utah PIs and administrative staff within all colleges, departments, and centers who are involved in the administration or conduct of sponsored awards that include subawards.
Roles and Responsibilities
Principal Investigator (PI) & Departmental Administrator
- Risk Awareness: Review subrecipient risk levels during the proposal stage and consult with OSP if a preliminary assessment is needed.
- Programmatic Oversight: Monitor the technical progress of the subrecipient and their ability to meet the stated objectives of the Scope of Work (SOW).
- Invoice Approval: Review and approve subrecipient invoices. Approval signifies that the PI or their designee has first-hand knowledge that the work being billed has been performed.
- Data Access (NIH Foreign Subawards): Ensure the University receives access to lab notebooks and data from foreign subrecipients at least once per year per NIH policy (NOT-OD-23-182).
- Escalation: Promptly report any performance or financial concerns to the Post-Award Compliance team.
Office of Sponsored Projects (OSP)
- Risk Assessment: Perform initial risk assessments for new subrecipients and periodic assessments for active entities.
- Agreement Drafting: Incorporate specific terms and conditions into subaward agreements based on the risk profile (e.g., requiring backup documentation for "High Risk" entities).
- Negotiation: Act as the primary point of contact for negotiating subaward terms with the subrecipient organization.
Post-Award Compliance & Grant Contract Accounting (GCA)
- Audit Verification: Verify annually that subrecipients have completed required Single Audits and that no findings exist that impact University of Utah awards.
- Training: Provide ongoing training and resources to the campus research community.
Definitions
Designee
An individual delegated by the PI to approve invoices, who must have direct knowledge of the project's progress.
Pass-through Entity
The University of Utah, when it provides a subaward to a subrecipient to carry out part of a federal program.
Subaward
A legal agreement for the performance of a substantive portion of a sponsored project. This does not apply to the procurement of goods or services from a vendor.
Subrecipient
An organization that receives a subaward and is accountable for programmatic decision-making and compliance.