Subrecipient Monitoring

The Office of Sponsored Programs is responsible for

• completing risk assessments for new subrecipients on federal awards annually,
• applying appropriate additional controls to medium and high risk subrecipients,
• reviewing problematic subawards identified by the PI or OSP and establishing additional controls as needed.

Research Financial Compliance (RFC) provides financial oversight of subrecipient activity by reviewing and approving invoices to ensure costs are allowable, allocable, reasonable and compliant with sponsor and prime award requirements.

RFC monitors and tracks subrecipient spending throughout the budget period to ensure expenditures align with the approved budget and period of performance.

Subrecipients may also be selected for a desk review to
assess compliance with sponsor award terms and applicable regulations.

At award closeout, RFC works with subrecipients to ensure timely submission of final invoices to support accurate financial closeout.

Below is a copy of UNT Health's subrecipient Monitoring Procedures. 

Subrecipient Monitoring
Procedures

Invoice Support

All costs must be supported by documentation showing that the expense is reasonable, allocable and allowable; within the grant limits; treated consistently; and determined in accordance with GAAP and the applicable cost principles in 2 CFR 200. Accounting records must trace back to source documentation, and UNT Health may request supporting documentation at any time. The level of documentation submitted with each invoice depends on the risk level the Office of Sponsored Programs (OSP) assigns to your organization. High-risk and selected medium-risk subrecipients may be asked to submit receipts and detailed support with every invoice. All subrecipients must retain appropriate documentation and provide it upon request.

Below is a list of general subrecipient expenses grouped by cost types and the supporting documents that may be requested.

Invoice Review

Knowing what the analyst checks can help you self-review your invoice before submitting. RFC confirms that:

• Subaward identifiers (Sub ID and PO) are accurate, and multi-year awards are charged to the correct PO.
• The billing period falls within the budget and project period.
• The invoice is not a duplicate of one previously submitted and paid.
• Budget categories and rates (F&A, fringe) agree with the approved subaward budget.
• Each category amount is reasonable and allowable per the agreement, the Uniform Guidance and UNT Health policy.
• A signed certification statement is included, and any final invoice is clearly identified.

If the analyst has a question about an expenditure, they will contact you to request additional information. The invoice is placed on "hold" status until the questions are resolved.

Desk Review Process

A desk review generally follows these steps:

1) Selection
RFC identifies subrecipients for review based on OSP's risk assessment, covering all high-risk and selected subrecipients.

2) Background Review
RFC reviews the subaward agreement, approved budget, risk assessment, submitted invoices, and other background information for the award.

3) Request to the PI
RFC sends a desk review request to the subrecipient's Principal Investigator (PI) and their subrecipient invoice contact.  

4) Examination of Expenditures and Controls
RFC reviews expenditures for compliance with federal, state, and institutional requirements. If the subrecipient's internal controls are not clear, RFC follows up with the PI to understand the subrecipient's processes and procedures.

5) Follow-up on Questioned Costs
RFC requests additional supporting documentation and clarification for any questioned costs, following up with the PI as needed.

6) Reports and Recommendations
RFC documents its observations, questioned costs, and any recommended corrective actions, then shares the results with the subrecipient and appropriate UNT Health personnel.

Preparing for a Desk Review

Subrecipients who maintain organized records throughout the award can respond to a desk review quickly and with minimal disruption. To prepare:

♦  Keep accounting records that trace to source documentation. Each invoiced cost should tie back to receipts, payroll records, or other support in your system of record.
♦  Have supporting documentation ready, such as paid receipts, payroll registers and effort certifications, travel logs and hotel folios, and vendor contracts and invoices.
♦  Confirm costs align with the approved budget and fall within the period of performance.
♦  Verify F&A and fringe were applied at the approved rates, and that any mandatory cost sharing is documented.
♦  Maintain written internal controls, policies, and procedures, and be ready to describe how your organization administers the subaward.
♦  Retain award records for at least three years from the date the final financial report is submitted (2 CFR 200.334), unless your award terms require longer.
♦  Respond promptly to requests for documentation or clarification, coordinating through your UNT Health PI.

Results of the Desk Review

At the conclusion of the review, RFC documents its observations, any questioned costs, and recommended corrective actions. Results of the desk review are discussed with the subrecipient's principal investigator and/or institutional leadership.

Where corrective action is recommended, RFC works with the subrecipient and the UNT Health PI to resolve the findings. Questioned costs may require additional documentation, and amounts determined to be unallowable may need to be removed or returned. These steps support UNT Health's responsibility, as a passthrough entity, to monitor subrecipients under the Uniform Guidance (2 CFR 200.331–.333).