Monitoring Subcontracts

Steps have been taken to improve and ensure UT PI involvement and oversight for progress, spending, payments and reporting on subawards. The Invoice Review process was outlined in greater detail and a Subrecipient Invoice Checklist was launched to accompany payment processing to improve compliance.

• The Office of Sponsored Projects has a dedicated team who's job it is to assess risk with proposed subcontracts.
   
  • This activity happens during the pre-award stage, before a subcontract is issued and it often includes additional requirements to gather financial disclosures from the would-be subrecipient. 
     
  • The steps involved with assessing risk can prolong the process of issuing a subaward, especially if, for example, the proposed recipient isn't very responsive, has a lot of questions or need for additional follow up, or is based in another country and may have different accounting standards compared to U.S.-based entities. 
     
• OSP Pre-Award team whose job it is to assess risk going in, there is also a team that continues to assess and monitor risk across the Post-Award stage.
  
  OSP's 'Grants Financial Management - Subrecipient Monitor' team is also responsible for monitoring risk with subawards, including activitysuch as:
   
  • Review and approve subrecipient invoices for payment.
  • Perform desk reviews of subawards as needed to evaluate subrecipient compliance with Uniform Guidance.
  • Maintain list of active subawards including risk level.
  • Annually collect Subrecipient Audit Certification form for on-going subawards.
  • Assist departments with monitoring the spend rate on subawards.
  • Assist departments and PIs with trouble shooting issues that arise.

The Office of Sponsored Projects Subaward Monitoring page lays out pre-award, award-stage and post-award roles and responsibilities. It's definitely worth checking out.

At the awarding stage (when the subaward subaccount is being set up in the main account along with its respective terms and conditions), the following is worth highlighting:

• The unit or department is obligated to require financial and technical reports from each subrecipient to adequately monitor progress and fulfill reporting requirements to the main (prime award) sponsor.
   
  • Progress reports should be provided in sufficient time to allow the subaward information to be incorporated into UT’s progress report to the sponsor. 
     
  • The UT Post-Award Specialist typically assists with creating the financial reporting but the PI is usually the one who pulls together and submits the project report.
     
• Review the Statement of Work (SOW), budget, period of performance, payment terms, and whether or not unspent funds are allowed to roll over (carry forward) into the next year.
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  • Again, the Research Administrator's role is to ensure compliance, so reviewing the details of the award goes a long way toward managing it efficiently.
     
• Review UT sponsor’s award terms and conditions with OSP and the subrecipient to ensure all requirements can be met by subrecipient.
   
  • This itypically happens between the OSP Subcontract team and the proposed Subcontract team with the Research Administrator copied on the exchange. 
     
  • If anything about the subcontract or its subaccount looks off or needs to be clarified, this stage is the time to do it - such as when there might be issues with the naming conventions in the subaward budget that may not have been categorized clearly (or correctly) based on what UT calls certain costing categories.
     

There is a recommendation on OSP's Subrecipient Monitoring site that each unit should craft a plan to monitor subcontracts that have been deemed high risk. 

Here's the list of duties at the Dept/Unit level, per OSP:

• OSP: Monitor subrecipient technical progress and adherence to terms of award and cost sharing requirements.
   
• OSP Review invoices. Please see the Invoice Review Guidelines below for guidance.
   
• OSP: Subaward Amendments - Assess need to modify statement of work, budget, period of performance.
   
• OSP: Plan for a timely closeout - check status with subrecipient 90 days before end date, follow up on any late or missing reports, ensure subrecipient submits a final invoice on time and marked FINAL.

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