Subrecipient Monitoring Procedures
A sub-recipient is the legal entity to which a sub-award is made and is accountable for the use of the funds provided to perform a portion of the work covered by a prime agreement.
Sub-awards do not include agreements for consulting services or purchase orders for equipment, materials or other service, which are considered vendor activity. Click here for further guidance.
Responsibilities: Principal Investigator
- Obtaining the signed agreement with sub-recipient and send copy to Grants Accountant. For assistance in developing the agreement, contact Grants Administration. At a minimum, the agreement must include:
- Performance period
- Programmatic goals and objectives
- Financial budget
- Key personnel
- Structure and frequency for financial reimbursement
Additionally, if funded directly or indirectly by federal funds, the agreement should include:
- Catalog of Federal Domestic Assistance (CFDA) number;
- Requirement for compliance to federal regulations, including applicable Cost Principles
and Uniform Administrative Requirements;
- If total federal funds received by the sub-recipient is over $500,000, an OMB Circular
A-133 audit must be obtained;
- For organizations that do not meet the threshold for an OMB Circular A-133 audit,
additional information regarding their financial systems should be obtained. Click here
for the financial questionnaire. Contact the Grants Accountant for additional assistance.
2. Reviewing the invoice(s) and supporting documentation submitted by the sub-recipient, to
ensure that the information is sufficient, charges are appropriate and correspond to the
identified objectives and budget of the agreement.
3. Periodic programmatic monitoring, and on-site visits, as necessary.
Responsibilities: Grants Accountant
- After receiving the executed sub-award, facilitating the discussion between Procurement Services and the Department regarding the setup of a purchase requisition and order for the sub-award. All sub-awards, because they involve the purchase of services, must follow the University’s purchasing policies related to contractual services. Click here to view the University’s purchasing policy (see Contractual Services on page 5).
- Tracking receipt of each sub-recipient's OMB Circular A-133 report, which are due nine months after sub-recipient’s financial year ends.
- Reviewing A-133 report for compliance to grant requirements and prepare a determination notice to the sub-receipient.
a. If corrective action is needed, a response must be requested from the sub-recipient.
The sub-recipient will be required to answer the response within a two week time frame.
b. The Grants Accountant must issue a final determination letter no later than six months
after the receipt of the sub-recipient’s A-133 report.
4. When applicable, provide GVSU’s third party cost sharing and in-kind forms. Ensure that
completed forms are received from the sub-recipient(s) in a timely manner.
5. Upon request of the Principal Investigator or University’s Controller, perform on–site visits when
circumstances warrant additional verification.
Page last modified April 18, 2014