Subcontract Monitoring Responsibilities
The Principal Investigator and Department Head are reminded that payments to the Subcontractor must meet the same criteria that
exist in the prime award. Expenditures must be allowable per the terms of the prime award and fall within the funding budget and
period for the Subcontract. Expenditures that are allowable under the terms of the prime award and the subcontract are only
reimbursable to a Subcontractor if they benefit the purpose of the Subcontract. The expenditures are required to be properly
The Principal Investigator is responsible for approving and authorizing payment to a Subcontractor. The subcontract requires that
financial reports be provided with invoices. It is the responsibility of the Principal Investigator to ensure the review and reconciliation
of invoices and the supporting documentation provided by the Subcontractor prior to the payment of invoices. In the event that there
are any questioned costs, additional supporting documentation shall be requested of the Subcontractor within five working days of
receipt of the invoice.
The department shall keep copies of invoices and all supporting documentation for payment of invoices on the Subcontract for at least
five years after the final closeout of the prime award.
If the Subcontract involves cost sharing, the Principal Investigator is responsible for ensuring that appropriate documentation related
to the cost sharing is obtained and maintained. For information related to the documentation guidelines for cost sharing, please see:
The Principal Investigator is reminded that all cost sharing and financial transactions of the University are subject to audit. Should an
audit of any transaction related to the Subcontract find that transaction to be unallowable, the transaction will be disallowed.
Disallowed costs are subject to repayment to the sponsor of the prime award. In the event that payment of disallowed costs have been
made to a Subcontractor and cannot be recovered from the Subcontractor, the Principal Investigator will be required to arrange for
repayment of the disallowed costs to the prime award sponsor.
Dependant upon the level of risk that has been assigned to a project by the Office of Research and Contract Analysis, it is the
responsibility of the Principal Investigator to perform the following monitoring activities:
Low Risk: In addition to the fiscal monitoring outlined above, the Principal Investigator should request and receive project
performance reports on a regular basis. Contact with subrecipients should be regularly maintained so as to be informed of progress or
barriers to progress.
Medium Risk: In addition to the fiscal monitoring outlined above, the Principal Investigator should request and receive performance
reports on no less than a quarterly basis. Contact with subrecipients through email, telephone, and other contacts should happen on a
scheduled basis. Principal Investigator may decide that site visits are required.
High Risk: In addition to the fiscal monitoring outlined above, the Principal Investigator should request and receive performance
reports no less frequently than monthly. Site visits and other forms of performance monitoring should be scheduled regularly
throughout the life of the Subcontract. Email, telecom, and other contacts shall be regularly scheduled. If schedules are being slipped
or costs are accelerating beyond anticipated, Principal Investigator shall attempt to determine the cause and work with subrecipient to
bring those issues into line.
Should the monitoring of the Subcontract result in the determination that the scope of work or the dollar value need to be changed,
please contact the Office of Research and Contract Analysis to initiate a contract modification.
I certify that I have read and understand the responsibilities shown above.
Principal Investigator Date Department Head Date