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Sub-Recipient and Sub-Award Monitoring

Clark University researchers often collaborate on funded projects with colleagues at other institutions, contractors providing services, and other organizations.  If Clark University is the prime recipient and a pass-through entity of funded awards with sub-awards, the University follows established policies and procedures.

As a prime recipient and a pass through entity of Federal awards, Clark University is required to monitor the activities of sub-recipients. In order meet the requirements of the Office of Management and Budget (OMB) Circular A-133 (Audits of States, Local Governments, and Non-Profit Organizations), the University shall perform the following with respect to sub-recipients/sub-awards:

  • Identify Federal awards made by informing each sub-recipient of CFDA title and number, award name and number, award year, if the award is R&D, and name of Federal agency. If any of this information is not available, the pass-through entity shall provide the best information available to describe the Federal award.
  • Advise sub-recipient of requirements imposed on them by Federal laws, regulations, and the provisions of contracts or grant agreements as well as any supplemental requirements imposed by the pass-through entity.
  • Monitor the activities of sub-recipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grants agreements and that the performance goals are achieved.
  • Ensure that sub-recipients expending $500,000 or more in Federal awards during the sub-recipient’s fiscal year have met the audit requirements of OMB A-133 for that fiscal year.
  • Issue a management decision on audit findings within six months after receipt of the sub-recipient’s audit report and ensure that the sub-recipient takes appropriate and timely corrective action.
  • Consider whether sub-recipient audits necessitate adjustment of the pass-through entity’s own records.
  • Require each sub-recipient to permit the pass-through entity and auditors to have access to the records and financial statements as necessary for the pass-through entity to comply with this part.

The Principal Investigator (PI) is responsible for monitoring the activities of the sub-recipient to ensure compliance with the progression of work, progress reports, technical reports and other deliverables by specified due dates.  Any concerns or issues related to sub-award or sub-recipient monitoring should be brought to the attention of OSPR.  PI is responsible for forwarding copies of the sub-recipient’s progress report and/or technical report(s) to OSPR.

Sub-recipient invoices submitted to the University must contain the following information:

  • Invoice must be on the sub-recipient’s letterhead
  • Date of invoice
  • Invoice number
  • Period of performance covered by the invoice
  • Itemized description of services and backup documentation
  • Current period costs, including cost sharing
  • Cumulative projects costs, including cost sharing
  • Sub-recipient contact person with respect to invoice
  • Invoice must be signed by an authorized official of the sub-recipient
  • Invoice must contain a certification that all payments requested are for appropriate purposes and in accordance with the agreements set forth in the application and award documents

The PI is also responsible for reviewing and approving invoices from sub-recipient(s) for adherence to the budget. The signature of the PI on the invoice indicates that the review has taken place and that the invoice adheres to the budget.

Contact Information

Sponsored Programs and Research

Office
  • Jefferson 5th Floor, Atwood
    Clark University
    950 Main Street
    Worcester, MA 01610

  • Lisa Gaudette, Director

  • 1-508-421-3835
  • lgaudette[at]clarku[dot]edu