Subrecipient Monitoring Responsibilities (OSP-AS, PI, OSP-FS)

Office of Sponsored Programs - Administrative Services (OSP-AS)

  1. Check the System for Awards Management (SAM) ( to ensure the subrecipient is not excluded from receiving federal funding.
  2. If federally-funded research or PHS or EPA funding, confirm that the subrecipient has completed an External Collaborator Certification or is registered in the FDP Institutional Clearinghouse. If the subrecipient certifies compliance with the JMU conflict of interest policy, ensure all identified investigators have an active JMU FCOI Disclosure Form on file and completed training.
  3. Conduct risk assessments for subrecipient organizations and notify the OSP Director of any with a high-risk rating. For “high-risk” subrecipients the subaward may include additional reporting and compliance requirements, such as monitoring visits, technical assistance, or periodic desk audits.
  4. Obtain an audit certification from the subrecipient prior to the full execution of the subaward and on an annual basis during the subaward period. Provide any related findings to OSP Director and OSP-FS. Review any audit reports findings, as well as review corrective actions cited by the collaborator in response to their audit findings.
  5. Validate the subrecipient's budget for proper rates and confirm the statement of work (SOW).
  6. Issue of award agreement including terms and conditions of Prime award, notification to sub of the option to perform on-site visits and "audits" if necessary, the inclusion of certifications, representations, and assurances, and notice of record retention policy (Standard FDP template will contain this information).
  7. Collect necessary information to meet FFATA requirements and submit it in the FSRS database, if applicable.
  8. Consideration of sanctions on a collaborator in cases of continued inability or unwillingness to have required audits or to correct non-compliant actions.
  9. Assist the principal investigator with prior approval requests needed for collaborators and issue modifications or amendments.

Principal Investigator (PI)

  1. Verify that work performed by the subrecipient is conducted in a timely and acceptable manner.
  2. Receipt and review of all deliverables (e.g. Technical Performance, Equipment, Invention Reports) with copies to OSP-AS.
  3. Review of expenses-to-budget and approval of collaborator’s invoices prior to forwarding them to OSP-FS for payment.
  4. Ensure subaward number is included on ALL accounting vouchers and invoices for proper and timely payment.
  5. Receive and approve cost share documentation from the collaborator, if applicable.
  6. Perform on-site visits or regular contact, as necessary.

Office of Sponsored Programs – Financial Services (OSP-FS)

  1. Monitor subrecipient for payments to make sure the subrecipient does not over invoice JMU. Some invoices are received in OSP-FS while others are sent directly to the PI’s department, but will be vetted by OSP-FS if the dollar amount is over $500.00.
  2. Approve payments to subrecipient.


  1. Follow appropriate record retention for up to 5 years after project closeout.


For questions or assistance with any activity, please contact the OSP. In all cases, the OSP expects the PI to be the first point of contact and to gather the details of any dispute with a collaborator.  OSP will intervene where appropriate and necessary.

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