San Francisco State University
Office of Research and Sponsored Programs
Subrecipient Monitoring Invoice Review Procedure
Prepared By:
Huron Consulting Group
Date:
6/29/2016
Business Process Description:
San Francisco State University (SFSU) is required by federal regulation to monitor expenses of federal
funds awarded to SFSU that are subcontracted to another institution (subrecipient). Requirements
include:
Audits of States, Local Governments, and Non-Profit Organizations (OMB Circular A-133). A-133
Subpart D (A-133.400 (d)(1-7)) includes the following subrecipient monitoring requirement:
 “Monitor activities of subrecipient as necessary to ensure that Federal awards are used for
authorized purposes in compliance with laws, regulations, and provisions of the contracts or
grants agreements and that performance goals are achieved.”
Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education,
Hospitals, and other Non-Profit Organizations (OMB Circular A-110) subpart A.5 states:
 “…the provisions of the circular shall be applied to subrecipients performing work under awards
if such subrecipients are institutions of higher education, hospitals, or other non-profit
organizations.”
Principals for Determining Costs Applicable to Grants, Contracts, and other Agreements with
Educational Institutions Subpart A.3 (OMB Circular A-21)
 “These principals shall be used in determining the allowable costs of work performed by colleges
and universities under sponsored agreements. The principals shall also be used in determining
the costs of work performed by such institutions under subgrants, cost reimbursement
subcontracts, and other awards made to them under sponsored agreements.”
To provide the monitoring required by the federal regulations and ensure good stewardship of sponsored
projects, SFSU will review all subrecipient invoice expenses for allowability and proper compliance.
Roles and Responsibilities:
Office of Research and Sponsored Programs (ORSP)
 Grants Support Coordinator (GSC): When a subrecipient invoice is received, the GSC
performs a review of the invoice. When ORSP and PI approval has been received and any issues
resolved, the GSC routes the invoice to Accounts Payable for approval and payment.
 Grant Administrator (GA): The GA completes a second review of the invoice and has approval
authority for any invoices under $5,000. Additionally, the GA is the primary resources to help
PI’s with any questions during this process.
 Post Award Manager: The Post Award Manager oversees the Subrecipient Invoicing Review
process providing assistance, guidance, and performance metric evaluation as necessary. The
GSC and GA report to the Post Award Manager. The Post Award Manager completes a Quality
Assurance review and signs all invoices between $5,000 and $10,000.
Page 1
DRAFT – HURON PROGRESS THROUGH 6/29/2016
San Francisco State University
Office of Research and Sponsored Programs
Subrecipient Monitoring Invoice Review Procedure

Director ORSP: The Director completes a Quality Assurance review and signs all invoices over
$10,000.
Academic Department
 Principal Investigator (PI): The PI has responsibility to ensure that expenses invoiced by the
subrecipient for work and effort committed complies with the Direct and Indirect Cost Charging
Procedure.
Accounts Payable (AP)
 Accounts Payable (AP): When a subrecipient invoice is received from ORSP, AP confirms that
the appropriate signatures have been obtained and, generates payment to the subrecipient for the
approved amount.
Business Process:
Subrecipient Institution:
1. The subrecipient submits an invoice by mail to the GA for payment. The contact information for the
appropriate GA is listed in the Terms and Conditions of each subcontract agreement.
Grant Administrator (GA):
1. When an invoice is received from a subrecipient institution, send the invoice to the GSC.
Grant Support Coordinator (GSC):
1. Obtain the blue subcontract folder created for each subcontract. The subcontract folder will include a
subcontract log printed on a blue sheet of paper attached to the front cover. Enter the following
information into the blue subcontract log located in the blue subcontract folder:
A.
B.
C.
D.
E.
F.
Date received
Invoice date
Invoice number
Invoice period
Invoice amount
PO (Purchase Order) balance
2. Review the invoice for appropriateness and accuracy.
A. Ensure that the invoiced period is within the contract period, and that any cost sharing
requirements have been met.
B. If unusual expense items are noted, discuss with the GA or the Post Award Manager to rectify
the situation. It may be necessary to contact the subrecipient to amend the invoice or to
obtain additional supporting documentation.
C. Initial the invoice once the expense review is complete and any issues have been resolved.
3. Send a copy of the invoice to the PI to perform a review of the charges.
Page 2
DRAFT – HURON PROGRESS THROUGH 6/29/2016
San Francisco State University
Office of Research and Sponsored Programs
Subrecipient Monitoring Invoice Review Procedure
Principal Investigator (PI):
1. Review the invoice for appropriateness with sponsor requirements and programmatic progress. If
there are no concerns, the PI will initial the invoice and send it to the GSC.
2. If concerns are found, the PI will contact the GA to discuss the unallowable or questionable items. If
necessary, the GA will request additional supporting documentation will be requested to justify
expenses. This includes receipts, supporting invoices, payroll information, and other supporting
documents.
Grant Support Coordinator (GSC):
1. The GSC will receive the invoice and any supporting documentation from the PI and ensure that the
invoice was initialed and deemed sufficient for payment.
A. Stamp the invoice and include the following information on the stamp:
i.
Project Number
ii.
Account Number
iii. Fund Number
iv. Department Identification Number
v.
Program Number
vi. Award Class
vii. Purchase Order Number
viii. Amount to Pay
2. The GSC then sends the PI approved invoice to the GA for a final review and sign-off.
Grant Administrator (GA):
1. The GA will review the invoice and any documentation before sign-off. The GA has sign-off
authority up to five thousand dollars. If the invoice is above the GA sign off authority, the invoice
will be routed to the Post Award Manager (between five and ten thousand dollars) or the Director (ten
thousand dollars or greater) for approval.
2. If the GA determines that an additional review is necessary, the GA will contact the GSC and the PI to
discuss a resolution.
3. Once the invoice is signed and approved for payment, the GA will return the initialed invoice to the
GSC for routing to AP.
Grant Support Coordinator (GSC):
1. Confirm the appropriate approvals have been received.
2. Record the “Date Sent to AP” on the blue subcontract log in the blue subcontract folder after it is
approved for payment.
Page 3
DRAFT – HURON PROGRESS THROUGH 6/29/2016
San Francisco State University
Office of Research and Sponsored Programs
Subrecipient Monitoring Invoice Review Procedure
3. Send the invoice to the ORSP Assistant to record the subcontract payment.
ORSP Assistant:
1. Log in the following information in the Document Management System (DMS):
Go to “In/Out Log” in DMS
Select the “Invoice” link
Select “New Item”
Enter the following information:
i.
Date Received
ii.
Invoice Amount
iii.
Invoice Number
iv.
Project Identification Number
v.
Account Code
vi.
Vendor Name
E. Select “Save and Close”
A.
B.
C.
D.
2. Log out the invoice and enter the following information:
A.
B.
C.
D.
E.
F.
Go to “In/Out Log” in DMS
Select the “Invoice” link
Select applicable invoice
Right click on the invoice link and select “Edit Item”
Enter the “Date Sent to AP”
Select “Save and Close”
3. Forward the signed and approved invoice to AP for payment by placing the invoice in the out box
designated for AP.
Related Processes/Events:
 Subrecipient Monitoring External Procedure
Page 4
DRAFT – HURON PROGRESS THROUGH 6/29/2016