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Subrecipient Monitoring

When the University of Utah issues a subaward, we are responsible for monitoring how those funds are used. We ensure compliance, manage risk, and support successful research partnerships. This page provides an overview of your responsibilities and the tools available to help you manage subrecipients with confidence.

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What is Subrecipient Monitoring?

The University of Utah is committed to the highest standards of research integrity and financial stewardship. When the University passes federal or private funds to a third party (a subrecipient) to carry out a portion of a sponsored program, we assume the role of a pass-through entity.

Under 2 CFR §200 (Uniform Guidance), specifically sections §200.331 and §200.332, the University is legally and ethically responsible for monitoring the programmatic and financial activities of our subrecipients.

OUR GOAL IS TO ENSURE THAT:

  • Sponsor funds are used for authorized purposes.
  • Performance objectives and technical milestones are achieved.
  • Subrecipients remain in compliance with federal laws, regulations, and the specific terms of the award.

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Roles & Responsibilities

Effective monitoring is a collaborative effort between central administration, departmental staff, and the research team.

Principal Investigator (PI)
Principal Investigator (PI)
Holds primary responsibility for the programmatic "health" of the subaward. The PI ensures the subrecipient is meeting technical milestones and reviews invoices to confirm that the work performed aligns with the costs charged.
Post-Award Compliance
Post-Award Compliance
Manages the high-level risk assessment process, updates institutional policies to reflect federal changes, and provides the necessary tools and training for the campus community.

The Subrecipient Lifecycle

The subrecipient lifecycle outlines the key stages of managing a subaward—from initial determination and risk assessment to ongoing monitoring and final closeout. Each step plays an important role in ensuring compliance, reducing risk, and supporting successful research outcomes.

1

Determination: Subrecipient vs. Contractor

Before an agreement is issued, we must determine the nature of the relationship. This classification is vital because it dictates the level of oversight required.

Feature Subrecipient Contractor (Vendor)
Purpose Carries out a portion of the programmatic effort. Provides goods or services within normal business operations.
Decision Making Has responsibility for programmatic decision-making. Operates in a competitive environment.
Compliance Must adhere to federal program requirements. Provides similar goods/services to many different purchasers.
Outcome Performance is measured against program objectives. Services are ancillary to the operation of the federal program.

2

Risk Assessment

The University conducts a risk assessment of every subrecipient prior to issuing a subaward. This assessment is not a "pass/fail" grade but a tool to determine the intensity of monitoring required.

Factors Include:

  • The entity's Single Audit (Subpart F) status and findings.
  • Financial stability and internal control systems.
  • Prior experience with the entity.
  • The complexity and size of the award.
  • Foreign entity considerations.

3

Active Monitoring & Invoice Review

Monitoring is an ongoing process. Throughout the life of the award, departments must perform regular reviews.

  • Technical Progress: PIs must receive and review technical reports regularly.
  • Invoice Standards: Invoices must reference the prime award, show current and cumulative expenses, and include a signed certification statement.
  • Financial Review: Costs must be allowable, allocable, and reasonable. Any discrepancies must be resolved before payment is approved.

4

Managing High-Risk Subrecipients

If a subrecipient is deemed "High-Risk," the University may implement Specific Award Conditions.

These may include:

  • Requirement for detailed expenditure backup (receipts, payroll records).
  • More frequent financial or technical reporting.
  • Site visits or "desk audits."
  • Payment on a strictly reimbursable basis.

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Closeout Responsibilities

The subaward is not "finished" until the final paperwork is reconciled. Prior to closeout, the PI and Department must ensure:

  • All deliverables and final technical reports have been received.
  • The final invoice is marked "FINAL" and matches the total expenditures.
  • Any patents, equipment, or inventory reports are properly filed.
  • The subaward is formally closed in the University's financial system.

Escalation Protocol

If a PI or department becomes aware of potential non-compliance, financial irregularities, or a failure to perform by a subrecipient, these concerns should be immediately escalated to the Manager of Post-Award Compliance. Early intervention is key to protecting the University's reputation and funding.

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