LSU Health Sciences Center Subrecipient Monitoring Policy
 Post Federal Award Monitoring during the Awarding Period

 Please follow LSUHSC-NO policies, unless the award has terms and conditions that are more restrictive.  The most restrictive sections from the LSUHSC-NO polices and award’s terms and conditions must be followed.

Subrecipient monitoring is required to ensure that the federal awards are administered according to the compliance of the laws, regulations, and provisions of contracts or grants agreements; and performance goals are attained.

Responsibilities:
Department Administrator and PI will be responsible for:

·	FFATA requirements – For all federal awards in which LSUHSC issue subcontracts, the department is responsible for obtaining all information that is pertinent to FFATA.  Additional information can be found  here.
•	Maintain an updated printed copy of the DUNS report at inception of contract or renewal 
·	Technical progress reports
·	Obtained prior approvals for re-budgeting
·	Subrecipient is submitting invoices on time
·	Document Regular Contact between LSUHSC-NO and Subrecipient
•	Subrecipient invoice must be paid in 30 days of receipt, otherwise documentation is required as to why the invoice could not be paid within the allotted time

Monitoring Subrecipient Expenditures
•	Ensure invoices are submitted in accordance with subaward requirements
•	Ensure that duplicate costs or invoices have not been submitted
•	Ensure invoices only contain expenses that are allowable, allocable and reasonable
•	Ensure other information required by contract have been received
•	Ensure Final invoice is marked “Final” 
•	Ensure Final invoice has a signed Certificate of Sub-Recipient attached
•	Verify cost sharing is appropriately reflected or attached to invoice, if required

Desk Audits or Site Visits
•	Desk Audit must be completed based on term of the subaward agreement
•	Requesting full documentation on an invoice (such as receipts, time and effort reports, time sheets and travel documentation)
•	Evaluate documentation provided
•	Evaluate Fringe and Indirect calculation charged on invoice
•	Obtain signed Certificate of Sub-Recipient 
•	Verify costs are incurred within the period of performance 

Clarification of invoice charges - PI and/or Business Manager must resolve any questionable charges prior to approval or submission of invoices for payment.  The Business Manager and/or PI should request clarification or detailed justification by the subrecipient for any charges which appear to be unallowable, unusual, or excessive.   If the PI or business manager feels that further review is necessary to process payment, they should contact Sponsored Projects.
Approval of Invoices – Business Managers/Assistant Business Managers and PIs will review invoices and expenses for allowability, reasonableness, and compatibility with the subaward budget and technical aspects of the award. PI will certify the invoices and Business Manager will indicate their approval of the invoices before submission for payment. 

Invoices received directly from subrecipient
•	Department reviews and approves invoices 
•	PI will review and certify invoices
•	Department forwards invoices to Sponsored Projects for final approval

         Invoices received from Sponsored Project
•	Department reviews and approve invoices
•	PI will review and certify invoices
•	Department forwards invoices to Sponsored Projects for approval
•	Sponsored Projects submits invoices to AP for payment

Invoice requirements- All invoices should include the following before being forwarded to AP.

•	LSUHSC project number
•	LSUHSC PO number
•	Departmental approval 
•	PI certification 
•	Sponsored Project approval
•	Final invoices should be stated as “FINAL” and a signed certificate of Sub-recipient                                             	should be attached

Travel and Equipment - should only be approved for items originally agreed upon in the subaward agreement. Should anything else arise, Subrecipient should request a re-budget or obtain prior authorization from LSUHSC-NO.  Please be mindful as to reasonableness and allowability.  See helpful links at the end of this policy

Change of Investigator –PI or Business Manager needs to ensure that any subrecipient change in Senior Investigator is reported to LSUHSC in writing.   

For-Profit or Foreign entities are accountable to the pass-through entity for the use of Federal
Funds provided.  These entities are not subject to the audit requirements of OMB Uniform Guidance.
 	To ensure for-profit sub recipient accountability for the use of funds, LSUHSC has the right to request backup documents for any invoice.

Office of Sponsored Projects will be responsible

· 	FFATA Reporting
•	Entity Questionnaire for Risk Assessment  will be sent out once a year to entities with current Subaward agreements
·	Uniform Guidance Audit Reports - §200.501- Once a year, (during second half of LSUHSC-NO’s Fiscal Year), Sponsored Projects will collect audit reports from subrecipient institutions to ensure subrecipients complied with the auditing requirements of OMB Uniform Guidance.    

·	Federal Clearing House- Once a year, Sponsored Projects will use the Federal Clearing House ( https://harvester.census.gov/facdissem/Main.aspx ) to verify that subrecipients on Federal Awards do not have any audit findings.

·	When sub recipients have audit findings – Sponsored Projects will request and follow up on any subrecipients who have audit findings. If necessary, Sponsored Projects will request subrecipient to provide audit responses and a timely corrective action plan.

•	For invoices with questionable expenses, Sponsored Projects may request a copy of the subrecipient’s ledger; and supporting documents.  Sponsored Projects may request the department to review any questionable expenses before approval.

•	Sponsored Projects may request a copy of the subrecipient’s audited financial statements.

Review of Subaward Invoices –

•	Invoices received directly from sub recipient
§	Sponsored Projects forwards invoices to department for initially approval.

•	Approved Invoices received from department
§	Sponsored Projects reviews invoices for reasonableness
§	Sponsored Projects approves invoices
§	Sponsored Projects forwards invoices to AP for payment

        Final Invoice

•	PI and department administrator are responsible for obtaining final closeout information, including final invoices, from their subrecipients.

Subrecipient monitoring

Subrecipient monitoring is required to safeguard the assets of the university and to ensure that performance goals are attained.  LSUHSC-NO conducts risk assessments on its subrecipients to help ensure that potential risks are identified and appropriate monitoring is conducted to mitigate those risks.  If the identified risks are significant, LSUHSC-NO can impose specific conditions (UG, § 200.207) during the course of the award.

Audit of Subrecipient(s)

As stated in agreement under Attachment 2, section titled “Audit”,  The Comptroller General of the United States or a duly authorized representative from the General Accounting Office or any other appropriate Federal agency, as well as the Legislative Auditor of the State of Louisiana and/or the Office of the Governor, Division of Administration, and/or Institution shall have access to and the right to examine any of the Subrecipient's directly pertinent books, documents, papers or other records involving transactions related to the Subaward.

•	Ensure that subrecipients expending $750,000 or more in Federal awards during the sub recipient’s fiscal year have met the audit requirements of OMB Uniform Guidance §200.501
•	Issue a management decision on audit findings within 6 months after the receipt of the subrecipient’s audit report
§   Review by Ella Lee for appropriateness
§	Review by Nicole Blanchard
•	Ensure that the subrecipients take timely and appropriate corrective action on all audit findings.
•	If a subrecipient is not willing or is unable to have the required audits, then LSUHSC will take appropriate action using sanctions.

No questionnaire and risk evaluation
If the questionnaire and the risk evaluation on a subrecipient have not been received, the subrecipient will be evaluated as high.  This will require full documentation to be accompanied with each invoice along with the High Risk Subrecipient Invoice Certificate form.

Helpful Links

1.	OMB Uniform Guidance
2.	Audit requirements section  - §200.501
3.	Allowability of costs explanation  - §200.403

4.	Reasonable costs explanation    - §200.404

5.	Allocable costs explanation    -  §200.405

6.	Subrecipient and contractor determinations  -  §200.330

Travel related references:
1.	LSU Travel Regulations – PM 13 – Effective July 1, 2015
2.	LSU Travel Pocket Guide – FY 15-16
3.	Federal Per Diem Rates by location

Revised  3/10/2016