Subrecipient Monitoring Notice
The following subaward/subcontract has been executed under DU Grant #: __________________
DU policy requires that subrecipients are monitored to provide reasonable assurance that the use of resources
is in compliance with laws, regulation, award terms, and that performance goals are achieved. The attached
checklist will serve as a tool to help determine compliance with this requirement.
Subcontractor Information
Subrecipient: __________________________________________________________________
Subcontract #: _____________________________ PO #: _____________________________
Project Name: _________________________________________________________________
Period of Performance: ________________________ to _______________________________
Monitoring Requirements
Principal Investigators (PI’s) and departments have primary responsibility for:
Establishing channels of communication with subrecipients
Ensuring performance goals are achieved;
Reviewing invoices from subrecipients for compliance with regulations and award terms and
conditions as needed based on subrecipient assessment
Reviewing and documenting performance; and,
Approving final invoices in a timely manner for closeout.
Upon audit or request, DU and the PI must provide documentation that monitoring has occurred.
This includes documenting correspondence and progress reports received. A sample template for a
“Subrecipient Monitoring Record” is attached.
Additional Requirements
This subrecipient has been designated a ____________ risk grantee. In addition to the above monitoring the
following will be required on this subcontract:
No additional monitoring required.
Invoices must be approved by PI.
Subrecipient monitoring record submitted to ORSP: ________________________
PI Site review required/submit to ORSP by: _______________________________
ORSP Desk/Site review by: ___________________________________________
________________________________________________________________ __________________
Assistant Controller, Research Administration Date
Subrecipient Monitoring Checklist
Has the subrecipient submitted the required reports in a timely fashion?
Document when performance reports were received. (See sample “Subrecipient Monitoring
Does PI make a periodic evaluation of subrecipient performance?
Is the PI satisfied with the performance? If no, contact subcontract and ORSP.
Did PI/program staff conduct a site visit? If so, is it documented?
Is the full scope of services listed in agreement being done? If deviation, document and
notify ORSP project administrator
Document any other ways subrecipient being monitored.
Program Income
If applicable is income properly recorded and deposited as collected?
Compliance Assurances
If project requires IRB, IACUC, or IBC has everything been approved?
If PI or key personnel has a relationship with sub, COI must be disclosed.
Satisfaction with Subrecipient
Be sure and summarize overall satisfaction with subrecipient. If problems, ORSP must be
Subrecipient Invoice Approval Checklist
Upon receipt of an invoice or request for payment from a subrecipient:
Review all submitted progress reports and financial reports received from the subrecipients.
Determine if all progress reports required to date under the terms of the agreement have been
submitted in an acceptable and timely manner.
Does the invoice have an institutional official signature certifying that charges are true and accurate
and/or for appropriate purpose.
Review the expenditures on the reimbursement request/invoice. Do the expenditures follow along
the same lines as what was budgeted or are there additional items listed that were not originally
budgeted for?
Do you see any potentially unallowable items listed in the reimbursement request such as
food/meals/entertainment/alcohol, etc. or items that should have been charged as an indirect cost
such as office supplies/general purpose computers/clerical and administrative salaries/postage.
Do the expenditures shown on the reimbursement request seem reasonable in relation to the amount
of time and work expected of the subcontractor to date? (For example, does it appear likely that they
will have spent a minimum of 75% of their budget by the time the current budget period has
concluded? Alternatively, does it look like they might exceed the amount available by the end of the
budgeted period? Are there appropriate reasons for such variations?) If something is amiss, follow
up with the subrecipient for an explanation.
Does it appear that there were charges that are not allocable to the project? (Such as travel costs to
places not anticipated in the scope of work or other charges or salaries for individuals not associated
with the work?)
If all required progress reports are up to date and acceptable, and the request appears reasonable
given the nature of the projects and amount of work completed to date, sign off on the invoice and
forward to ORSP for approval for payment.
Please note: by signing off and approving an invoice, you are attesting that the subrecipient has
been appropriately monitored and has met all of the conditions of #1 above. If you have any
doubts, please do not approve and go to Step #3 on the next page.
If progress reports are not up to date and acceptable, or you see something that does not appear
right, do not forward the invoice for payment. Instead, immediately contact the subrecipient and
ask for missing or unacceptable reports to be sent and/or request additional documentation as
necessary and appropriate. Once issues have been acceptably resolved, and/or, if necessary, a
revised request has been submitted by the subrecipient, you can forward the reimbursement request
or invoice to ORSP for approval for payment.
Note: Most invoices/reimbursements do not include a large amount of detail, but, if something does
not appear right on the surface, our contracts allow us the right to ask the subrecipient for back-up
documentation for specific budget line items, especially for high-risk agreements.
Subrecipient Monitoring Record
PI Name Subrecipient
DU Grant # Sub PI
Contract/PO# Sub Contact
Performance Period Project Invoicing Mo Qtr Other
Person responsible for this record:
Scheduled Reporting Dates (based on the terms of the award)
These should be filed with the grant files in the department and retained in the same manner as other grant documents.
6/1/15 Annual progress report 5/28/15
6/1/15 Annual progress report 5/26/15
6/1/14 Annual progress report 5/29/14
*dates entered as each report is submitted
Informal Progress Reports Completed (these should generally take place at least quarterly)
6/20/14 Email with PI Hiring process delayed because of
ARRA hires taking priority
7/15/14 Email with PI New hires started last week and
project now in full swing.
11/1/14 Telephone call with PI Discussed that start up process
was on schedule and equipment
purchased per scope
3/20/14 Email between Post Docs Samples collected successfully
and will be shipped today.
6/10/15 Telephone call with PI Data is looking promising.
Remaining samples should be
collected by 7/1/10(on schedule)
10/7/15 Site Visit Discussed the progress of the
entire study.