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Reminder

Compliance protocols MUST be approved and linked in SeRA to a SPO project record prior to award acceptance. 

See ORA's Award Acceptance Resources for additional information.

Managing a Subaward

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Monitoring a Subaward

Stanford is responsible for ensuring that sponsor funds, including those provided by Stanford to other entities, are spent in accordance with all applicable terms, conditions, laws and regulations, and that subrecipients are risk assessed and monitored prior to contracting and throughout the life of the award.

Principal Investigator & Departmental Responsibilities for Monitoring Subawards

It is the PI’s responsibility to monitor their subawards throughout the life of the project so there is reasonable assurance that the subrecipient uses the award for authorized purposes, complies with laws, regulations, and the provisions of the agreement, invoices Stanford for allowable expenses in accordance with the agreement, and achieves its performance goals. PI’s and administrators should be familiar with the subaward agreement, sponsor requirements, and the subrecipient budget to ensure appropriate enforcement.

The PI and department administrators should obtain invoices in a timely manner and manage and monitor the subaward invoice payments on the purchase order to ensure invoices are posted timely and to the correct award, task, and line. 

Invoice Review and Signature

Invoices should be generated by the Subrecipient and signed by the Subrecipient’s authorized official.  If the prime sponsor is federal, invoices must include the following certification language (if the invoice is missing the certification, it should be returned for correction):

By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (U.S. Code Title 18, Section 1001 and Title 31, Sections 3729-3730 and 3801-3812).

The department or PI must review the subrecipient’s invoices, and the PI must indicate approval by personally signing each invoice for payment and including the certification language below on each invoice. If the PI is not on site to sign the invoice, the email approval or electronic signature must include the certification language and be attached to the invoice when uploaded for payment. The department administrator must upload the invoice for payment in iProcurement within 85 days of the task or award end date to ensure the invoice posts to the award, rather than the suspense PTA. 

In signing below I approve payment of 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.

Stamps with the above language printed on it for affixing on an invoice can be ordered by emailing the JP Cooke sales department directly at sales@jpcooke.com and request the stamp ordered by Stanford University Dept. of Sponsored Research on February 7, 2013.

As part of the invoice review, the PI and departmental administrators may consult the Invoice Payment Checklist tool prior to payment, and must verify that the invoice was prepared in accordance with the subaward requirements and that invoiced costs are:

  • In accordance with the approved budget or permissible rebudgeting
  • Incurred within the approved period of performance and overall cost limitations (invoices for subaward periods not yet obligated to the subrecipient via contractual Amendment may not be paid, even if sponsor time and funding is received)
  • Aligned in terms of cost and type of expense with the scientific progress reported to date
  • Allowable, allocable, and reasonable
  • Include the subrecipient signature and certification (if federal)
  • Include a current and cumulative total and breakdown by major cost category
  • Have the subaward number which matches the PO number in iProcurement
  • Includes any cost sharing (if applicable)

Clarification of Invoiced Charges:  In the event the level of detail included on an invoice is not sufficient, or if it appears that some costs may be excessive, unallowable, or understated, the PI or departmental administrator should question the subrecipient's expenditures by requesting further documentation or explanation prior to approving an invoice.  If the explanations are not sufficient to render a prudent judgment on the allowability of costs, and the terms of the subaward permit, department grant administrators may request detailed justifications from subrecipient.  Department administrators may also periodically request, if the terms of the subcontract permit, particularly from high-risk subrecipients, detailed support for selected invoiced charges to verify their appropriateness and reasonableness.  Such inquiries must be done in a timely manner (e.g., within thirty days after receipt of an invoice) so that the subrecipient can be promptly paid for their approved costs.

Examples of detailed justifications that may be requested from subrecipients include: payroll records, receipts, copies of paid invoices showing the cost of items purchased, descriptions of services rendered by consultants, including hourly rates, time reports and details of incurred travel charges stating the purpose, airfare, meals, ground transportation, unallowable costs, etc. Copies of all such documentation and the ultimate outcome of the investigation should be retained in the project file.

When there is a concern about the allowability of cost, the administrators can contact OSR for coordination of subsequent actions. OSR staff are available to assist the PI and their departmental staff in resolving any invoice review issues that may arise.

Technical Progress & Compliance

The 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 current human and animal subjects approval when applicable. The subaward monitoring and compliance obligations of the PI may be shared with department administrators or other Stanford employees; however, in no event may such monitoring and compliance obligations be delegated to a non-Stanford employee.

Quarterly Review & Certification

At quarterly review and certification, the PI certifies the allowability, allocability, reasonableness, and consistency of the subrecipient's expenditures and the related sufficiency of the subrecipient's technical progress under each subaward involved in the research project, as well as expenses incurred directly at Stanford.

Financial Monitoring and Management

The PI and department are responsible for ensuring subrecipient invoices are received timely, are reviewed, signed, and certified, are uploaded in a timely manner (prior to task and award closure), funding is available on the PO, and invoices are applied to the appropriate PTA. Departments should use the Requisition and PO Query tool in iProcurement to monitor and manage each subaward and track invoices. Invoices that are uploaded after task or award closure will post to the department’s suspense PTA and iJournals are not permitted on active subawards.

Regulations and Assurances

In addition to terms and conditions of the sponsor, University Policy, federal, state, and local laws, and contractual requirements, Stanford is subject to the requirements of Uniform Guidance CFR Part 200—Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards which dictate many of Stanford’s subaward processes, policies, and procedures. If the sponsor is a federal contract, the FAR regulations will apply.

Department Subrecipient Monitoring – Making all the Right Moves recording

Department Subrecipient Monitoring – Making all the Right Moves slides