Subrecipient Monitoring – PI Responsibilities

The PI is responsible for:

• verifying that work performed by the subrecipient is conducted in a timely manner and is acceptable;
• reviewing and approving subrecipient invoices (to be forwarded by the ORSP Sponsored Programs Accountant);
• maintaining regular contact with the subrecipient regarding the technical aspects of the project;
• performing site visits as necessary to review fiscal and programmatic records and/or observe programmatic activities; and
• ensuring that all deliverables (e.g. technical, equipment, and invention reports) required under the subaward are being provided.

Subrecipient Monitoring – ORSP Responsibilities

The ORSP is responsible for:

• evaluating subrecipients' risk of noncompliance to determine appropriate level of monitoring;
• identifying subrecipients that have been suspended or debarred from receiving federal funding;
• informing each subrecipient of the CFDA title and number, award name and number, and name of the federal agency providing funding;
• advising subrecipients of the requirements imposed on them by federal laws, regulations, the provisions of the prime award, or provisions of UM;
• ensuring that non-profit subrecipients expending $750,000 or more in federal awards during the subrecipient’s fiscal year have met the audit requirements of 2 CFR Part 200, Subpart F;
• issuing a management decision (when subrecipients have audit findings) within six months after receipt of the subrecipient’s audit report and ensuring that the subrecipient takes appropriate and timely corrective action;
• considering whether subrecipient audits necessitate adjustment of UM’s own records;
• requiring each subrecipient to permit UM and auditors to have access to the records and financial statements as necessary for audit purposes;
• reviewing and approving subrecipient invoices and forwarding them to the PI for review and approval; and
• performing desk audits and/or site visits as necessary for review of subrecipient financial records; and
• obtaining a Small Business Subcontracting Plan from the subrecipient if a subaward is on a federal contract incorporating the Small Business Subcontracting Plan requirement, the amount of the subaward is $700,000 or more AND the subrecipient is not a small business.