Georgia Tech is responsible for ensuring that all subrecipients of its sponsored research awards are in compliance with applicable requirements.
In accordance with OMB Uniform Requirements (2 CFR 200), Georgia Tech is required to monitor all subrecipients expending $750,000 or more in federal awards during the subrecipients' fiscal year where pass-through federal funds provided by Georgia Tech were expended.
These guidelines and procedures are provided to assist faculty and staff in ensuring that subrecipients conduct their portions of research projects in compliance with laws, regulations, and terms and conditions of awards and subawards and that project costs incurred by subrecipients are reasonable and allowable.
Roles and Responsibilities
Principal Investigators (PI)
PIs have primary responsibility for monitoring subrecipients to ensure compliance with federal regulations and both prime and subrecipient award terms and conditions. The federal government places the primary responsibility for management of federally funded projects with the PI. This includes:
- Monitoring of subrecipient’s technical and programmatic activities related to the subaward
- Review of technical/performance reports as required
- Verifying that the subrecipient work is conducted in a timely manner and that the results delivered are in line with the proposed statement of work
- Reviewing and approving subrecipient invoices, including expenditures to ensure the charges are allowable, allocable, reasonable, and within the period of performance
- Maintaining regular contact with the subrecipient
Unit Financial Officers (Departmental Administrators)
Unit Financial Officers (UFOs) should assist PIs in carrying out their subrecipient monitoring responsibilities. This includes:
- Reviewing invoices from subrecipients to ensure invoices are within the parameters of the subaward budget and questioning expenditures if necessary
- Ensuring that invoices are approved by the PI or his/her designee and submitted to Accounts Payable on a timely basis
- Requesting clarification from the subrecipient regarding any unusual or excessive charges invoiced by the subrecipient
- Maintaining copies of all invoices that provide evidence of the regular review of invoices by the PI
- “Evidence” can be in the form of authorized signature by the PI or his/her designee, PI’s initials, e-mail communications, or notes of meeting between the PI with the department administrator.
- Maintaining documentation of monitoring efforts (copies of e-mails, phone log, etc.)
Office of Sponsored Programs (OSP)
OSP is responsible for the oversight of subrecipient monitoring and ensuring that the Institute’s subrecipient monitoring procedures are compliant with federal and other applicable regulations. These responsibilities include:
- Identifying to the subrecipient the federal award information (e.g., CFDA title and number, award name, name of federal agency) and applicable compliance requirements, including any appropriate flow-down provisions from the prime agreement
- Determining whether the subrecipient or its PIs are debarred or suspended from receiving federal funds
- Annually reviewing all active subawards for which monitoring is mandated
- Accordingly, OSP requests audit certification letters from all subrecipients expending $750,000 or more in federal funds during the subrecipient’s fiscal year.
- The returned certification letters are reviewed by the OSP Audit Coordinator to verify that no audit findings related to federal funds provided by Georgia Tech are reported.
- If no findings are indicated, the OSP Audit Coordinator will initial, date, and notate that no follow-up action is required.
- OSP will inquire further into those that are deemed to require closer scrutiny and will take appropriate action.
The above list is not exhaustive of all compliance requirements. In addition to the general elements of compliance noted above, additional sponsor- or program-specific requirements may mandate collecting and documenting other assurances (e.g., on lab animals, human subjects, biohazards, etc.) during the course of a project.
OSP will work with PIs and department administrators to establish channels of communication with subrecipients that require further scrutiny.