UW Research
Policies, Procedures and Guidance

GIM 08 – Subrecipient Monitoring

Purpose

The University of Washington (UW) has a long tradition of working closely with collaborative institutions, nonprofit, and industry partners on sponsored programs. These relationships often take the form of a pass-through entity (UW) and a subrecipient (collaborator). This GIM directly relates to Sponsored Program Subaward Administration GIM 7 which addresses policy for the administration of subawards issued by the University under a prime award (contract, grant or cooperative agreement) made to the University.

When the UW issues a subaward to a subrecipient, there is a responsibility for subrecipient monitoring.

Background

At the time of proposal submission, the UW represents to the prime sponsor that all activity, including that of the subrecipient, will be carried out consistent with sponsor requirements. This requires the UW to assess and monitor our subrecipients before and during a subaward.

University Policy

Subrecipient monitoring is performed at both the entity and project levels and occurs throughout the lifecycle of the subaward. This is a shared responsibility among central administration, the UW Principal Investigator, and the campus unit administrative staff. Subrecipient monitoring requirements include:

  • Completion of an entity level comprehensive risk assessment of each subrecipient
  • Subrecipient acceptance of subaward terms and conditions
  • Receipt of regular invoices and progress reports from subrecipient
  • Financial, administrative, and programmatic review followed by approval/rejection of subrecipient entity’s invoice through approved UW systems
  • Maintain records according to UW and sponsor retention requirements
    • This may include the subaward agreement, subrecipient entity progress reports, approved invoices, back-up documentation, etc.

Before a subaward or subaward modification can be executed, the subrecipient must provide the necessary information or documentation to successfully carry out a full risk assessment and/or complete a compliance review.

If UW PIs and subrecipient PIs encounter disputes including non-performance, non-compliance challenges, or interpretation of subaward terms that cannot be resolved, the UW PI must escalate to the OSP Subawards Team. OSP may involve other UW and subrecipient central offices, the Prime Sponsor, or WA State Attorney General’s Office as needed.

Subrecipient Monitoring Plans

On a case by case basis, at OSP’s discretion, OSP may require a documented subrecipient monitoring plan signed by the UW PI prior to issuance of the subaward.

Roles & Responsibilities

Principal Investigator/Campus Unit

Project level monitoring of subrecipient including

  • Monitor subrecipient technical progress & performance.
  • Monitor subrecipient adherence to terms & conditions.
  • Verify compliance approvals are current for subrecipient portions of the statement of work.
  • Ensure that all required reports and or documentation are received.
  • Work closely with subrecipient to ensure timely invoices. Late invoices received past the final invoice due date set out in the terms & conditions are subject to rejection.
  • Review invoices & approve for payment according to UW Finance invoice approval instructions.
  • Reviews that expenses are necessary, reasonable, and allocable to the work completed and are aligned with technical progress. (see GIM 23)
  • Ensure best practices are in place for other monitoring activity which may include regular check-in, teleconferences, site visits, regular check-ins, etc.
  • Escalate potential cases of non‐performance, non‐compliance, or subaward interpretation disputes with the subrecipient to the Subawards Team, in the UW Office of Sponsored Programs.
  • Provide & follow subrecipient monitoring plans as requested based on OSP’s discretion on a case-by-case basis.

Office of Sponsored Programs

  • Obtain necessary information or documentation from the subrecipient and UW PI to successfully carry out a full risk assessment and/or complete a compliance review.
  • Perform subrecipient entity-level risk assessment.
  • Incorporate special terms & conditions based on subrecipient entity-level risk assessment as needed.
  • Issue a management plan to subrecipient if necessary.
  • Request & approve specific subrecipient monitoring plans for PI/campus unit to follow on a case-by-case basis at OSP’s discretion.
  • Verify that corrective action plans have been implemented by subrecipient if necessary.
  • Review escalation requests & take appropriate action which may involve coordination with other UW and subrecipient central offices, the Prime Sponsor, or WA State Attorney General’s Office.

Subrecipient

  • Provide necessary information or documentation to the UW PI and OSP.
  • Perform & comply with applicable terms, conditions, regulations & deadlines.
  • Coordinate with UW PI and OSP if a dispute arises.
  • Submit invoices timely and according to UW procedures.

Related Resources

Change Notes

Details on changes to this GIM are available from the Office of Sponsored Programs, osp@uw.edu