Policies and Procedures
The policy also outlines the responsibilities of the Principal
Investigator in assuring both programmatic and fiscal compliance of
subrecipients to the terms and conditions established by the
This policy seeks to:
As required by OMB Circular A-133, all subawards issued by the
University shall provide the best information available to describe
the award, including:
The University is obligated to advise subrecipients of
requirements that are imposed on them by federal laws, regulations,
and the provisions of the sponsored project award document.
Subrecipients are required to permit the University and its auditors
to have access to records and financial statements pertaining to
Except in unusual cases, subrecipients must be identified in the
proposal submitted to the sponsoring agency. Following the
execution of subawards, the University is required to monitor the
subrecipient's activities to ensure that activities are conducted
in compliance with regulations and that performance goals are
achieved. In general, when a significant percentage of an award is
passed through the University to a subrecipient, more intense
monitoring is necessary. Regular communication with the
subrecipient is required.
The University shall monitor subrecipients to ensure compliance
with audit requirements. If audit findings are revealed, the
University shall issue a management decision within sixty days
following the receipt of the subrecipient's audit report and
confirm that the subrecipient has taken appropriate corrective
actions in a timely manner. If the subrecipient's corrective action
plan is not submitted to the University within thirty days, the
subrecipient will receive a follow-up phone call or email from the
school's budget officer, or the OGSP grants officer. If the
corrective action plan is not received by the end of sixty days, a
letter will be sent from the Associate Provost. After ninety days,
a letter will be sent from University Counsel to inform the
subrecipient that failure to respond may result in the termination
of the subaward.
If the subrecipient's audit findings necessitate adjustments in
the University's financial records, such adjustments shall be made
in a timely manner.
The Office of University Counsel shall review all subawards with
variations from the approved subaward template. University Counsel
shall work with the Principal Investigator and OGSP and/or the
school's budget officer to negotiate changes to proposed subawards
prior to their execution.
COMMUNICATION WITH SUBRECIPIENT
The Principal Investigator shall maintain sufficient contact
with the subrecipient to assess accurately whether the subrecipient
is adequately performing the statement of work and reasonably
progressing towards the achievement of the performing goals.
REVIEW OF TECHNICAL PERFORMANCE REPORTS
The Principal Investigator shall obtain periodic written
performance reports from the subrecipient. Such reports should
generally contain a comparison of actual accomplishments with the
goals and objectives established for the period.
REVIEW OF FINANCIAL INVOICES
Depending on the scope of the work and level of involvement from
the subrecipient, site visits are often necessary to ensure an
effective collaboration. The Principal Investigator shall arrange
and maintain documentation for such visits.
FINANCIAL DISCLOSURE STATEMENTS
Grants and Sponsored Projects Main Page
Policies and Procedures
Office of the Provost29 Everett StreetCambridge, MA 02138(617) firstname.lastname@example.org