When a sponsored award includes a subaward to another institution, the Principal Investigator/Project Director of the sponsored award has obligations to oversee the subrecipient’s activities on the project. As the person most familiar with the subrecipient’s performance—through e-mail/telephone conversations, technical meetings, progress reports, site visits, etc.—the PI/PD is responsible for monitoring a subrecipient’s technical and scientific performance, and for reviewing invoices from the subrecipient to determine the appropriateness of the invoiced costs. The following guidelines are to assist PI/PDs in the fulfillment of invoice review responsibilities.
The subrecipient is responsible for submitting periodic invoices to the PI/PD/department administrators for the costs incurred on the subrecipient project activities. Our standard subaward template requires, at a minimum, quarterly invoices from each subrecipient. If the PI/PD is experiencing difficulty in receiving timely invoices, then the PI/PD can contact the Office of Sponsored Projects, Research Subcontracting and OSP will assist with communications to the subrecipient to established a regular invoicing schedule.
The subrecipient is responsible for retaining supporting documentation for the invoiced costs and to provide copies of such documentation upon request. The subrecipient is required to retain copies of the supporting documentation for a period of 3 years or as required by the sponsor after the end of the subaward period of performance.
At the conclusion of a subaward, the subrecipient is responsible for submitting a final invoice that the subrecipient marks as “Final.” Our standard subaward template requires the subrecipient to submit the final invoice within 60 days of the end date of the subaward.
PI/PD and Department Administrators Responsibilities:
The department is responsible for setting up a mechanism to monitor subaward project activities and progress, and to monitor invoice reviews and payments.
Upon receipt of an invoice from a subrecipient organization, the PI/PD is responsible for reviewing, approving, and authorizing payment of the invoices. Department Administrators may assist with the review process, but the PI/PD is responsible for approving each subrecipient invoice prior to processing a payment.
Prior to approving a subaward invoice, the PI/PD should review the invoice to determine the following:
- All invoiced costs are allowable costs under he grant award;
- All invoiced costs are reasonable costs consistent with the subrecipient’s accomplishments during the invoice period;
- All invoiced costs are allocable to the subrecipient’s activities under the subaward Scope of Work.
If an invoice includes costs that require clarification before an allowability, reasonableness, or allocability determination can be completed, then the PI/PD and Department Administrators should contact the subrecipient to request the clarifications. The PI/PD and Department Administrators are responsible for retaining documentation of this communication for the subaward grant record.
If an initial request for clarifications does not answer all questions about the invoice, the PI/PD and Department Administrators can contact OSP, Research Subcontracting to discuss the remaining questions and determine a course of action.
The PI/PD should not approve an invoice for payment until all questions have been resolved, and the PI/PD has sufficient information to make an allowability, reasonableness, and allocability determination for the invoiced costs.
Once an invoice is approved, the recommended best practice is for the PI/PD to sign the invoice or indicate by email that the invoice is approved and may be paid. The department is responsible for retaining a copy of each invoice and its corresponding approval, as well invoice background information, if applicable.
In accordance with the federal Uniform Guidance found at 2 CFR 200.305(b)(3), the Department is responsible for reviewing, approving, and paying each properly submitted subrecipient invoice within 30 calendar days of receipt.
The department is also responsible for reviewing cost share commitments of subrecipient organizations. When a subrecipient has agreed to cost-share on a subaward project, each invoice should identify the level of cost-share committed during the invoice period. The department is responsible for tracking the progress of the subrecipient towards completing their cost-share commitments. If the PI/PD and Department Administrators experience difficulties with a subrecipient’s inability to report on the cost-share incurred during an invoice period, the department can contact OSP Research Subcontracting to determine a course of action.
The PI/PD’s approval of a final invoice is a critical step in the proper close-out of a subaward agreement. When reviewing a Final invoice, the PI/PD should only approve and authorize payment of a Final invoice if the PI/PD is satisfied that 1) the subrecipient has completed its performance under the subaward budget period; 2) the subrecipient has submitted all required reports and/or other deliverables to the PI/PD; and 3) the costs incurred are appropriate for that performance. If the PI/PD is in any way dissatisfied with any of these three categories, then the final invoice should not be paid until these matters are resolved.
Office of Sponsored Projects, Research Subcontracting Responsibilities:
OSP Research Subcontracting can assist by communicating with the central offices at a Subrecipient organization when the subrecipient is not complying with the invoicing terms and conditions of the subaward agreement. This can include non-compliance related to timing of invoice submission, non-compliance related to the provision of supporting documentation, non-compliance with fulfillment of their cost-share commitments, etc
Dated: March 26, 2019
Revised: October 31, 2022