Tufts University takes a risk-based approach to subrecipient monitoring, focusing monitoring efforts more frequently on those subrecipients who are deemed to pose a greater risk for potential non-compliance.
Principal Investigators (PIs) and Local Research Administrators (LRAs) use the following subrecipient monitoring procedures when appropriate:
PIs communicate regularly with subrecipient PIs and review progress/programmatic reports or other specified deliverables on a timely basis to ensure the subaward funds are being used for authorized purposes and that performance goals are being achieved. Any issues should be investigated, documented, and resolved by the PI.
LRAs monitor receipt of progress/programmatic reports or other deliverables for timeliness and are responsible for alerting their Pre-Award point of contact timely of any performance, financial, or other issues related to an existing subaward. Certain issues may prompt Pre-Award to add additional terms to the subaward via an amendment.
PIs and/or LRAs perform an expense to budget comparison for cost-reimbursement subawards. The subrecipient’s invoices are generally required to show both current period and cumulative expenses.
PIs and/or LRAs are responsible for reviewing and documenting the review of financial reports and invoices received from the subrecipient to ensure that they are in compliance with Federal statutes, regulations, and the terms and conditions of the subaward. By signing the invoice, the PI is confirming that the costs are reasonable, allowable, allocable, reflect the work performed and are in accordance with the terms of the subaward agreement. If the PI chooses to have a designate sign the invoices, the individual must have first-hand knowledge of the project in order to judge the quantity and quality of the work represented on the invoices. Once the PI or his/her designate signs, the invoice should be returned to the appropriate Post-Award Specialist. S/he approves the invoice and forwards it to Accounts Payable for payment under the assigned purchase order number. The Subrecipient Invoice Checklist should be used as a guide for reviewing subrecipient invoices.
PIs and/or LRAs are responsible for verifying that the subrecipient is adequately meeting any cost sharing commitments made under the terms of the subaward and that the subrecipient's indirect costs as charged are in compliance with the indirect cost rate specified in the subaward.
LRAs should request that the subrecipient provide clarification of invoiced charges that appear unusual, excessive, or otherwise questionable. LRAs may request detailed justification to verify the costs are allowable.
For subrecipients identified as requiring closer scrutiny, PIs and LRAs should work with the OVPR to establish additional channels of communication and monitoring methods.
PIs should communicate with Pre-Award and Post-Award regarding any change in expectations of performance of work, payment terms, change in key personnel, reporting requirements, budgeting, deliverables, etc. If work stops or a change in the scope of work results, Pre-Award and Post-Award should be notified and appropriate agreement changes implemented.
OVPR uses the following subrecipient monitoring procedures:
Invoices received from sub-recipients are required to include specific certification language that can be found under CFR 200 Subpart E 200.415 to assure that expenditures are proper and in accordance with the terms and conditions of the award and approved project budgets.
Post-Award is responsible for reviewing and signing invoices received from the subrecipient to ensure that they are in compliance with Federal statutes, regulations, and the terms and conditions of the subaward. The Subrecipient Invoice Checklist is used as a guide for reviewing invoices.
The OVPR verifies that subrecipients if applicable, are audited as required by the Audit Requirements in the Uniform Guidance and will review the subrecipients’ audit reports to assess audit findings, if any.
The OVPR will issue a management decision for audit findings that relate to awards Tufts makes to subrecipients. For single audit organizations a management decision must be issued within six months of acceptance of the audit report by the Federal Audit Clearinghouse.
The OVPR is responsible for following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies provided to the subrecipient directly related to Tufts prime awards detected through audits, on-site reviews, and other means.
For subrecipients not subject to Audit Requirements of the Uniform Guidance, audited financial statements and/or completion of a financial controls questionnaire will be requested.
OVPR unit coordinates continued subrecipient risk assessment and subrecipeint monitoring to ensure a comprehensive, linked approach. During annual assessments, Subrecipient Compliance Specialist analyzes the subrecipient audit documentation and any relevant information from departments to ensure that the risk rating for each subrecipient is appropriate. The determinations of risk are communicated to PIs and LRAs, along with any additional requirements and need for special monitoring.
The subrecipient risk level (low, medium, or high) is recorded in the organization’s record in RAS based on the institution risk level. The Subrecipient Compliance Specialist updates subrecipient risk level in RAS upon completion of each RAQ. Subrecipient risk level will also be updated during the continued risk assessment based on the review of the annual audit information.
OVPR provides training and guidance in interpreting regulations and subrecipient award terms and conditions.