A Tableau report that shows pending invoices is automatically sent on Mondays to LRAs who have not yet returned subaward invoices sent for review by Post-Award. If an invoice exceeding the PO is present on the report, a request to increase the PO must be submitted as soon as possible.

• If an invoice exceeds the existing PO by 10% or $200 (whichever is less) it will continue to move forward.
• Invoices exceeding the PO by greater amounts will create a match exception and the invoice owner will be notified via email from PeopleSoft. Match exceptions are not posted and the expense is not recognized until the PO is increased.

The system does not send out payment confirmations. Normally an invoice is paid after it has been approved by the Due Date or the Preferred Payment Date listed in invoice details. The Due Date is a date calculated by the system by adding the number of days from the subaward payment terms in PeopleSoft to the date on the invoice. The Preferred Payment Date may override the Due Date if an invoice needs to be paid sooner than the Due Date. Accounts Payable can move up the Preferred Payment Date, which will initiate payment sooner. The following are the only two reasons when the payment is delayed:

• The invoice is approved after the Due Date/Preferred Payment Date. If this is the case, the invoice will get paid in the next payment run.
• A match exception has occurred if the invoice exceeds the PO over the threshold or the award is closed or frozen. The invoice owner will be notified.

All subaward invoices are first received by Post-Award and are distributed by the Financial Administrative Coordinator to the LRA assigned to the award. Invoices received via the electronic system arrive from the email address info@email.mediusflow.com. Post-Award uses “Send for Review” action in the system to redistribute the invoice to the LRA for review so that the LRA can obtain the PI’s signature - however the responsibility for approving or rejecting the invoice remains with the Post-Award.

Tufts is required to pay the subrecipient invoices under federal awards within 30 days per CFR 200.305(b)(3) that states:

“…the Federal awarding agency or pass-through entity must make payment within 30 calendar days after receipt of the billing, unless the Federal awarding agency or pass-through entity reasonably believes the request to be improper.”

Therefore, it is important to review the invoices expeditiously to ensure that Tufts University is in compliance with the federal regulations. Reviewed invoices including the approval of the PI/designee that has first-hand knowledge of the project activities should be returned to Post-Award within two weeks. Post Award Specialist assigned to the award will perform the final review and submit the invoice for payment.

Local Research Administrator (LRA) Review
The LRA confirms that the PO amount is not exceeded by the invoice and reviews the invoice for the following:

• Confirm alignment with the approved subaward budget and the scope of work
• Ensure that the rate of spending is consistent with the timeline of the project. Any indicators of over- or under-spending should be discussed with the PI prior to approval of the invoice
• Verify that the expenses on the invoice are allowable and in compliance with the subaward and prime award terms
• If additional monitoring reports are required by the subaward terms, ascertain that those reports have been received.

After performing their review, the LRA shares the invoice with the PI or a PI’s designee who has first-hand knowledge of the project activities. It is the LRA’s responsibility to obtain the PI’s or their designee’s approval of the invoice. A copy of the PI/designee approval must be uploaded into the system. This will be stored with the invoice as an audit trail of the approval.

Principal Investigator (PI) Review
The PI or their designee with first-hand knowledge of the project activities must confirm the following:

• That the invoice expenses are consistent with the project objectives and agree with the work completed
• If applicable, that the progress report accompanying the invoice is acceptable.

The PI/designee must either sign the invoice or provide evidence of authorization through other means (such as email) that the invoice has been reviewed and is approved. A sample statement of the PI/designee attestation is as follows:

“I have reviewed the attached invoice or financial report. Both the work being performed and the expenses reflected on this invoice and/or financial report are consistent with the scope of work.”

Post-Award Review
Post-Award specialist review consists of the following:

• Confirm that the invoice is sequential and the invoice period is within the period of performance
• Confirm that the invoice date complies with the invoicing requirement in the subaward agreement
• Ensure that cumulative expenses do not exceed the total approved subaward budget
• Confirm that the invoice totals correctly
• Ensure that the subrecipient’s Facilities & Administration (F&A) costs are calculated correctly with the correct and agreed upon rate and base, including:
  • that invoiced F&A costs are only applied to expenses that can accrue F&A based on the subrecipient’s F&A rate/methodology
  • that invoiced F&A costs are applied according to the sponsor terms and/or level of F&A allowed by the sponsor.
• Verify that the invoice is signed by the subrecipient’s institutional official and, for all federal subawards, contains the following statement per 2 CFR 200.415:

By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise.

Invoices under federal subawards that do not contain the required statement are returned to the subcontract organization for revision.