As the prime award recipient, UCI has the responsibility to ensure that sponsor funds, including those subawarded by UCI to other organizations, are spent in accordance with all applicable laws and regulations. This means regular monitoring of subrecipient’s programmatic and financial activities. The subrecipient monitoring starts at the prime proposal stage and ends when a subaward is fully closed.
PI & Department Responsibilities for Monitoring Subawards
It is the UCI PI’s responsibility to monitor subrecipients so there is reasonable assurance that the subrecipient uses the award for authorized purposes, complies with laws, regulation, and the provisions of the agreement, invoices UCI for allowable expenses in accordance with the agreement, and achieves its performance goals. Although UCI PIs have primary responsibility for monitoring the above, it is understood that some responsibilities are frequently delegated to departmental staff or carried out by Contracts & Grants Accounting (C&G Accounting) or SPA.
Invoice Review and Signature
The UC PI must review the subrecipient’s invoices and indicate approval by personally signing each invoice certifying that performance goals were met and authorizing payment. Certification may be evidenced by including the following sample language on each invoice:
“In signing below, I approve payment on this invoice and attest that charges appear reasonable and progress to date on this project is satisfactory and in keeping with the statement of work.”
As part of the invoice review, the UCI PI and department administrators should verify that the invoice was prepared in accordance with the subaward requirements and that invoiced costs are:
In accordance with the approved budget
Incurred within the approved period of performance and overall cost limitations
Aligned in terms of cost and type of expense with the scientific/technical progress reported to date
Allowable, allocable, and reasonable
In the event the level of detail included on an invoice is not sufficient to fully understand the costs, or if it appears that some costs may be excessive or understated, the UCI PI or department administrator should question the subrecipient’s expenditures by requesting further documentation or explanation prior to approving an invoice. Such inquiries must be done in a timely manner so that the subrecipient can be promptly paid for approved costs. Departments should contact C&G Accounting or SPA when there is concern about the allowability of cost.
Technical Progress & Compliance
The UCI PI must be in contact with the subrecipient regularly to discuss technical progress, receive and review required reports or deliverables, and verify that the subrecipient maintains up to date compliance approval and assurance (e.g., human and/or animal subjects approval) when applicable.
Initiating Subaward Amendment
During the subaward period of performance, it may be necessary to amend the terms of an existing subaward. The UCI PI can initate an amendment by completing a SRF and attaching applicable documentations (e.g., revised budgets, dates, SOW) and emailing it to SPA. Generally, an amendment is required for these changes:
Increase or decrease funding
Revision of the subaward period of performance
Modification or addition terms and conditions
PI change for prime awardee or subrecipient
Change of scope of work or budget
It important to note that some changes may require the prior approval of the prime sponsor before the change can be initiated to the subaward (e.g., change in scope of work, change in the subrecepient’s principal investigator, or transfer of the subaward from one recipient to another).
Upon receipt and review of the completed SRF, SPA will draft the subaward amendment. Additional negotiation of the subaward terms may be necessary and may require UCI PI involvement. Upon final agreement between UCI and the subrecipient, SPA will obtain a partially executed amendment from the subrecipient. Before the subaward amendment can be signed by UCI, a purchase order amendment (POA) must be initiated in the Kuali Financial System (KFS) by the department financial administrator and a POA finalized. For assistance creating POAs, please contact KFS@uci.edu.
All subawards should be closed out when its period of performance comes to an end, regardless of whether UCI’s prime award is ending or continuing. When feasible, it is advisable for a subaward period of performance to be slightly shorter than UCI’s to allow sufficient time for collection and review of the subrecipient’s final reports, verification of subrecipient data, and incorporation of the subrecipient’s research results into UCI’s final technical report to the prime sponsor.
UCI PIs are responsible for obtaining final technical reports and the final invoice* from their subrecipients, and retaining a copy in their project file. UCI PIs are encouraged to remind subrecipients of this need well in advance of the due date for such reports. Other final reports, including equipment forms, patent reports, and release documents may be required.
*Subrecipients are required to submit a final invoice, clearly marked “Final”, to UCI by the date that is required in the subaward agreement.