D. Subrecipient Monitoring

Monitoring is a shared responsibility:

• Programmatic Monitoring (PI Responsibility): The PI is responsible for monitoring the subrecipient's technical progress, reviewing all technical reports, and maintaining regular contact to ensure the work is proceeding as planned and meeting project objectives.
• Financial and Administrative Monitoring (ORI & Finance Responsibility): ORI and the Division of Finance & Administration are responsible for reviewing and processing all subrecipient invoices, ensuring costs are allowable and consistent with the approved budget, and monitoring the subrecipient for compliance with financial and administrative award terms. Additional monitoring may be imposed on entities deemed to be high-risk.

E. Subaward Closeout

At the end of the project, the PI must ensure all final technical reports and deliverables have been received from the subrecipient. ORI and the Division of Finance & Administration will ensure all final invoices have been received, paid, and that the subaward is formally closed.

Responsibilities

• Principal Investigator (PI): Responsible for identifying the need for a subrecipient, providing the technical scope of work, monitoring the subrecipient's programmatic progress, and approving their invoices for payment based on satisfactory progress.
• Office of Research & Innovation (ORI): Responsible for making the final subrecipient vs. contractor determination, conducting the risk assessment, issuing and negotiating the subaward agreement, and providing ongoing administrative oversight.
• Division of Finance & Administration: Responsible for financial monitoring, processing invoice payments, and managing financial reporting and closeout related to the subaward.

REFERENCES AND RELATED MATERIALS:

• Uniform Guidance, 2 CFR § 200.331–333, “Subrecipient Monitoring and Management”
• KSU Financial Conflict of Interest in Research Policy

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HISTORY: