Managing a Subaward
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
Invoice Requirements for the Subrecipient
Invoices should be generated by the Subrecipient and signed by the Subrecipient’s authorized official. If the prime sponsor is federal, the subaward invoices must include the below certification language. If the certification language and/or the authorized official signature is missing, the invoice must be returned to the subrecipient for revision.
Each subaward invoice uploaded for payment needs to include the following information:
- Compliant invoice (see Invoice Requirements for the Subrecipient)
- PI statement of approval and attestation
- PI signature
- PO line(s) to which the invoice payment should be applied
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 below certification language on each invoice.
If the PI is not on site to sign the invoice, an electronic approval by email or electronic signature may be utilized. The electronic approval must include the certification language and be attached to the invoice when uploaded for payment.
The upload process accepts one PDF document for each invoice, and the PDF may have multiple pages. If the invoice and approval are more than one page, please combine the pages into a single PDF for upload.
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. Invoices submitted after this time period will post to the department's AP Default PTA.
As part of the invoice review, ORA encourages the PI and department administrators to leverage the Invoice Payment Checklist tool prior to payment.
The PI and department administrators 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 current and cumulative totals 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 department 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 administrators may request detailed justifications from the subrecipient.
Department administrators may also periodically request, if the terms of the subaward permit, particularly from high-risk subrecipients, detailed support for selected invoiced charges to verify their appropriateness and reasonableness. Inquires for additional support for invoiced charges should be submitted to the subrecipient within thirty days of receipt of any subaward invoice.
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 costs, the administrators can contact ORA for coordination of subsequent actions. ORA is available to assist the PI and their department staff in resolving any invoice review issues that may arise.
Custom stamps of the PI approval and attestation statement can be ordered by emailing the JP Cooke sales department directly at email@example.com. Request the stamp ordered by Stanford University Dept. of Sponsored Research on February 7, 2013.
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.
NIH Subaward/Consortium Lab Notebook Requirements for Foreign Entities
Effective January 2024, the National Institutes of Health updated the requirements for data in support of technical progress as reported in the project RPPRs for foreign subrecipients. NIH Notice NOT-OD-23-182 provides the final guidance for this updated requirement. The additional guidance provided by NIH affects proposal documentation, the written subaward agreement, and the monitoring activities of the Stanford PI.
- NIH expects recipients to ask potential subrecipients at the application stage to submit language in their letters of support indicating 1) their awareness of these requirements and 2) the subrecipient’s willingness to abide by all requirements should an award be issued.
- For foreign subrecipients, a provision requiring the foreign subrecipient to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic.
What does this mean for Stanford Investigators and Departmental Administrators?
To meet the NIH requirements, Stanford has implemented the following:
- Stanford's Subrecipient Statement of Collaborative Intent (OSR Form 33) includes the required proposal certification. A complete and institutionally endorsed OSR Form 33 is required to be obtained from each proposed subrecipient on NIH proposals prior to proposal submission to the NIH.
- Letters of support provided by subrecipients proposed on Stanford NIH proposals must include a statement of their awareness of the requirements in NIH Grants Policy Statement (GPS) Section 15.2 and NOT-OD-23-182, and their intent to abide by those requirements should an award be issued.
- For Stanford faculty providing letters of support where Stanford is the subrecipient, we recommend including the following language in the letter.
- Stanford is aware of the NIH requirements in the NIH Grants Policy Statement, Section 15.2, and in NOT-OD-23-182, and is willing to abide by all requirements should an award be issued.
- Subaward agreements include a provision requiring the foreign subrecipient to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to Stanford with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report (RPPR) submission. Such access may be entirely electronic.
- Stanford investigators are responsible for ensuring they have the required access. They will be required to certify they have the required access to data from each foreign subrecipient during the RPPR process.
Any questions regarding the technical monitoring and compliance requirements for subawards should be directed to the OSR Subaward Team.
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.