Subrecipient Monitoring

A relationship with a subrecipient is documented in a formal agreement that is negotiated on behalf of the University of Michigan and an authorized representative of the subrecipient organization. OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) (“Uniform Guidance”), specifically §200.331, requires pass-through entities to monitor the activities of subrecipient organizations to ensure that the subaward is in compliance with applicable Federal statutes and regulations and terms of the subaward. Post-Award Subrecipient Monitoring refers to day-to-day activities undertaken to monitor scientific progress and billing of an active subaward. The Office of Contract Administration (OCA) is responsible for preparing and executing outgoing agreements. The PI is responsible for monitoring the subrecipient’s (subcontractor’s) performance and costs by:

  • Maintaining regular contact with the subrecipient PI regarding all technical aspects of the project.

  • Ensuring that deliverables required per the statement of work are being completed and provided.

  • Reviewing and approving subrecipient invoices in a timely manner.

  • Certifying that work performed by the subrecipient is being completed and is acceptable (submitting concurrence coversheets in a timely manner).

  • Informing OCA of any changes in the subaward agreement (e.g. dollar amount, award period etc.)

  • Communicating any deliverable or performance related issues to OCA.