Subrecipient Monitoring Checklist

The Office of Management and Budget for Grants and Agreements under Part 200 - UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS Subpart D - Post Federal Award Requirements stated the Monitoring and Management of subrecipient.  A subrecipient is the entity that receives a subaward from a pass-through entity (PTE) to carry-out a portion of the federal award.

Sections 200.331 (a) (b) 200.207 200.331 (d) to (e) subpart F and  200.338 referenced the compliance requirements imposed by the Federal Government on Award Notification, Risk Assessment, Specific conditions, Monitoring, and Non-compliance respectively.

Checklist to Determine Subrecipient or Contractor Classification See Form here

Invoice Checklist See Form here

Subrecipient Close-out

The final stage in the grant lifecycle is grant closeout (please see 2 CFR Part 200 Sections 200.343 thru 200.345 for the guidelines).  When CSU issues subawards, subrecipients have the same close-out responsibilities as CSU.  These are awards made to other organization/s for the performance of a portion of the work of a CSU sponsored project.  

Procedures

On the post award stage, CSU close-out marks the end of the project award relationship.  This is a process where CSU finalizes the completion of all administrative actions and stated required work on a project.

Subaward Closeout 

Purpose:  Close out a subaward on a sponsored program. 

Applicability:  CSU Principal Investigators (PIs) involved in sponsored research with subrecipients on a grant.

  1. A termination of account memorandum should be forwarded to the appropriate departments (PI, GAG, Budget Dept., OGRA, and Purchasing Department) 90 days before the grant expires (200.343).
  2. An email notice of grant close-out should be forwarded to the appropriate subrecipients.
  3. Verification that the final invoice has been received from the subrecipient no later than 60 days following the grant termination date.
  4. A verification from PI that the final technical report has been received (in writing, unless an exception has been approved). The PI is responsible for approving the final technical report and retaining it for inclusion in the final technical report to the prime sponsor.
  5. A verification from PI that a patent/invention report has been received, if applicable.
  6. A verification from PI that property report has been received , if applicable.
  7. After full payment of final subrecipient invoice, close all (unexpended balance) Purchase Order.
  8. Retain Subrecipient Close-out Checklist on file
  9. Retain financial and technical records pertaining to the subrecipient for 3 years or the number of years required by the sponsor, whichever is longer.

Close-out Checklist

See Form here