Subrecipient Monitoring

Subrecipient monitoring is the process by which the Drexel selects, monitors, controls and accounts for subrecipients (sometimes referred to as subcontractors) utilized on funded projects in accordance with federal regulations.

The integrity of the subrecipient monitoring system is integral to Drexel's compliance process, which was established jointly between the Office of Research and the Office of the Comptroller.

For grants and contracts, subrecipient monitoring is a risk-based monitoring process that mitigates the risk that organizations may inappropriately charge the sponsor(s) for services that were never provided, services that were inadequate or did not meet grant requirements, services that were mispriced, services that were not negotiated in an arms-length transaction, or other unallowable charges.

This guideline establishes the requirements for subrecipient monitoring related to sponsored projects in accordance with federal regulations, other agency regulations, and a proper system of internal accounting controls in accordance with Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Requirements for Pass-Through Entities (2 CFR 200.331) (Uniform Guidance).

The principal investigator, their department/college, the Office of Research and Office of the Comptroller Research Accounting Services share the responsibility of ongoing monitoring of subrecipients. Guidelines have been developed to assist with dissemination of the Project Specific Form and collection of the required information.

• Guidelines for Drexel investigators and staff
• Guidelines for subrecipient organizations
• Roles and responsibilities of each party are outlined in the policy: Compliance with Subrecipient Standards of OMB Uniform Guidance