Harvard University is responsible for monitoring the programmatic and financial activities of its subrecipients to ensure proper stewardship of sponsor funds. The PI is primarily responsible for ensuring that the subrecipient is meeting the programmatic objectives of the project. The PI and Department/Local Level Managing Unit provide administrative and financial oversight of the subrecipient to confirm that the subrecipient invoices align with the project deliverables.
For subawards under federal prime awards, Harvard must comply with OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR §200) ("Uniform Guidance"), specifically sections §200.330 and §200.331, that require prime recipients of federal funds to monitor subrecipients and to ensure subrecipients meet the audit requirements in Subpart F and use funds in accordance with applicable laws, regulations and terms of the award.
To meet that responsibility Harvard has convened a University Subrecipient Monitoring Committee to manage subrecipient monitoring across all schools (HUSMC). The primary goals of the HUSMC are:
- Update policies and procedures to reflect any federal changes to subrecipient monitoring
- Manage the risk assessment process for the University ensuring that risk assessments of all subrecipient organizations are complete before entering into a subaward agreement
- Development of tools and resources to help ongoing monitoring in the departments
- Develop and conduct training and outreach
- Advise on policy and manage escalated concerns