MIT is responsible for monitoring the programmatic and financial activities of its subrecipients in order to ensure proper stewardship of sponsor funds. For subawards under federal prime awards, we must comply with OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR §200) ("Uniform Guidance"), specifically sections §200.330 and §200.331, that require prime recipients of federal funds to monitor subawardees and to ensure subrecipients meet the audit requirements in Subpart F and use funds in accordance with applicable laws, regulations and terms of the award.
RAS will review the business and financial qualifications of each subrecipient organization to determine the risk level. Reviews are carried out annually and adjusted as necessary. RAS will work with principal investigators (PIs) and department (DLCI) administrators to craft an appropriate management plan for high-risk subrecipients.
PIs have primary responsibility for monitoring subrecipients to ensure the responsible stewardship of funds, including:
- Authorizing the Subaward, including funding level, period of performance and scope of work
- Certifying that work performed by the subrecipient is complete and acceptable:
- “To the best of my knowledge, I certify that the subawardee’s invoice costs appear reasonable and fairly correlates with the technical progress made on this research project.”
- Maintaining regular contact with the subrecipient PI regarding all technical aspects of the project
- Ensuring all deliverables required under the subaward agreement are being completed and provided
- Reviewing and approving subrecipient invoices in a timely manner
- Communicating problems with reporting, inappropriate spending, or deliverables to department administrator or financial officer and RAS
DLCI administrators assist PIs in carrying out their subrecipient monitoring responsibilities.
At Proposal Stage:
- Identifying the risk level of the subrecipient organizations using the Kuali Coeus (KC) database and seeking advice from RAS for potential subawards to high risk organizations
- Securing budgets, scope of work and letters of endorsement from the Subaward organization
- Making a preliminary determination whether the collaboration is a Subaward or vendor relationship – note that an incorrect classification could lead to additional costs to the project.
At Award Stage:
- Providing up to date scope of work, budget and other supporting information as needed
- Ensuring that invoices are approved by the PI or the PIs designee and returned to RAS in a timely basis
- Requesting clarification from the subrecipient regarding any unusual or excessive charges invoiced by the subrecipient
- Maintaining copies of all invoices that provide evidence of the regular review of invoices by the PI
- “Evidence” can be in the form of an authorized signature by the PI or the PIs designee, PI’s initials, e-mail communications, or notes of meeting between the PI with the department administrator.
- Maintaining documentation of monitoring efforts (copies of e-mails, phone log, etc.)
Research Administration Services (RAS)
RAS is responsible for the oversight of MIT’s subrecipient monitoring program and ensuring that the Institute’s subrecipient monitoring procedures are compliant with federal and other applicable regulations. These responsibilities include:
- Maintaining a database of organizations, including relevant information (name, address, federal identifiers, status in SAM and Harvester)
- Annually reviewing and assessing the level of risk of organizations and making a high/low risk determination for each organization
At Proposal Stage:
- Making the final subrecipient / vendor determination for each new Subaward
- Sending questionnaires to potential new subrecipients and making a preliminary risk assessment; notifying PIs and subrecipients of high risk determinations
At Award Stage:
- In coordination with the PI and DLCI head, developing risk mitigation strategies for high risk subaward organizations, enabling collaborative research to be carried out and the responsible stewardship of sponsored funds
- Identifying to the subrecipient the award information (e.g., CFDA title and number, award name, name of federal agency) and applicable compliance requirements.
- Developing and issuing subawards to subrecipients with the appropriate terms and conditions, including any appropriate flow-down provisions from the prime agreement.
- Reviewing subrecipient invoices to ensure they meet the following standards prior to sending to the PI and DLCI for approval:
- Invoiced amounts are within the available funds limits and within the approved period of performance
- Cost share requirements are being reported in accordance with the approved budget
- Labor and indirect cost rates are in accordance with the approved budget
- Charges comply with the terms and conditions of the award
- Ensuring all closeout reports have been received, the final invoice has been paid, and the PO is closed out properly.