Responsibilities of UC Davis sub-recipients
As the prime recipient of a grant, UC Davis may collaborate with other institutions, known as sub-recipients, who carry out a portion of the project. Sub-recipients can receive funding in the form of a sub-award from the prime award.
Federal guidance requires prime recipients of federal funds to monitor sub-awards to ensure sub recipients meet the audit requirements and use funds in accordance with applicable laws, regulations, and terms of the award.
UC Davis is therefore responsible for monitoring the programmatic and financial activities of its sub-recipients in order to ensure proper stewardship of sponsor funds. Policy and Procedure Manual (PPM) section 330-31 addresses institutional responsibilities and assists Principal Investigators and staff to ensure that, in addition to achieving performance goals, sub-recipients comply with Federal laws and regulations and with the provisions of any agreements that govern the sub-award. PPM 330-31 applies to all sub-awards issued under sponsored programs made to the university, without regard to the primary source of funding.
- Principal Investigator (PI) or Project Director (PD) will monitor sub-award performance to ensure compliance with award terms and conditions and satisfactory performance of the sub-recipient's portion of the project.
- PI/PD should review technical performance reports or other specified deliverables on a timely basis. Any unforeseen issues should be documented, investigated, and resolved.
- PI/PD and local administrator(s) should perform an expense-to-budget comparison for cost-reimbursement sub agreements.
- PI/PD will review and authorize payment of sub recipient invoices to verify the completeness and acceptability of work performed, the reasonableness of expenditures, and fulfillment of any cost-sharing commitments.
- Sub-recipients not subject to Circular A-133 may require additional monitoring by local administrators to ensure compliance.
- PI/PD and/or local administrator may at their discretion conduct on-site visits to evaluate compliance with the project's scientific objectives, and the appropriateness of the sub-recipient's administrative systems, processes, and charges.
- Sponsored Programs Office (SPO) will process sub-awards, ensuring specific prime award identification and contract provisions flow down into the sub-award. SPO will also perform A-133 monitoring for new award applications and amendments.
- Contracts & Grants Accounting (CGA) will review sub recipient payment requests for evidence of PI authorization.
There are two options for PIs to assess whether payments to sub recipients are appropriate and document their approval.
- PI reviews and approves the invoice, documenting with signature on the invoice. The invoice is scanned into the financial system as support for the payment, or
- PI reviews and approves the invoice, and communicates the approval via email. The invoice and email approval are scanned into the financial system as support for the payment.
PIs and Administrative Units must be prepared to demonstrate their compliance with the sub recipient monitoring policies in PPM 330-31.
- OMB Circular A-110 § .26 Non-Federal Audits
- OMB Circular A-110 § .51 Monitoring and Reporting Program Performance
- OMB Circular A-133 § .200 Audit Requirements
- Uniform Guidance § 200.331 Requirements for Pass-through Entities
- Uniform Guidance § 200.501 Audit Requirements
- Policy and Procedure Manual § 330-31