Subrecipient Monitoring Checklist
When part of your project is carried out by another institution, you issue a subaward, and you take on responsibility for monitoring that subrecipient. This checklist covers the obligations the prime recipient owns.
Getting the subrecipient-vs-contractor call right is step zero.
Before the subaward
- Determine subrecipient vs. contractor: a subrecipient does substantive programmatic work; a contractor provides goods or services.
- Assess the subrecipient's risk (audit history, prior performance, systems).
- Confirm the subrecipient's registrations and single-audit status.
In the agreement
- Flow down the prime award's applicable terms and conditions.
- Define scope, budget, reporting, and invoicing requirements.
- Set F&A treatment: only the first $25,000 of the subaward counts toward your MTDC base on NIH awards, or $50,000 where the 2024 Uniform Guidance applies and your rate agreement cites it.
During the project
- Review subrecipient invoices against the budget and progress before paying.
- Collect technical and financial reports on schedule.
- Follow up on any single-audit findings relevant to your award.
At closeout
- Collect final invoices and reports from each subrecipient.
- Reconcile and deobligate remaining subaward funds.
- Document your monitoring for the record.
Common pitfalls
- Treating a subrecipient like a vendor, or a vendor like a subrecipient, which changes F&A and compliance responsibility.
- Paying invoices without reviewing them against the subaward budget and reported progress.
- Skipping a risk assessment before issuing the subaward.
The prime recipient is accountable for its subrecipients: monitoring isn't optional, and it starts before the money moves.
Frequently asked questions
What is the difference between a subrecipient and a contractor?
A subrecipient carries out a substantive part of the research and makes programmatic decisions; a contractor or vendor simply provides goods or services. The classification drives monitoring and F&A.
What monitoring is required?
A risk assessment before award, review of invoices and technical reports during performance, and ensuring required terms flow down to the subrecipient.
How does a subaward affect F&A?
Only the first $25,000 of each subaward is included in the MTDC base on NIH awards and under older rate agreements, or the first $50,000 where the 2024 Uniform Guidance applies and your rate agreement cites it. Overhead is not charged on the remainder.
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