FloridaAtlantic University
Division of Research
Subcontract and Monitoring Guidance Grid
Principal Investigator (PI)
Sponsored Programs (SP)
Research Accounting (RA)
BEFORE Issuance of Subcontract
1. Determine the need for subcontracting:
a. Identify a subcontractor; or
b. Issue a Request for Proposal (RFP)
2. Potential subcontractors are required to fill out
Subaward Application:
a. Subaward Application Form includes:
□ Scope of Work
□ Detailed Budget
□ Financial Conflict of Interest
□ Financial Profile
Note: If a subcontractor application has not
been submitted in full during the
proposal stage, an application will be
required in order to issue a subcontract
agreement.
3. Review and approve subcontract application,
and forward to SP for further approval.
4. Upon approval from SP, the PI will request
a Letter of Intent (LOI) from the subcontractor
to be submitted withthe proposal.
1. Review Subcontract Application for
eligibility:
1. Assist Pre-Award with risk assessment
regarding A-133 Audit Reports.
a. Verify if the contract is the acquisition of
goods and services to determine a vendor
from a subcontractor
b. Verify ifthe organization is debarred
c. Budget evaluation (cost analysis) to
determine allowability, allocability and
reasonableness
d. Review most current A-133 Audit (contact
RA for assistance, if needed)
e. Determine if there are export control
issues
f. Determine financial conflict of interest
g. Assess level of risk associated with the
proposed subcontractor (low, medium, high)
2. Inform PI of approval and the risk level
assessed. If risk level is “high,” then
General Counsel is required to approve
3. Upon receiving award notification and
approval, SP will negotiate an agreement
with the subcontractor
4. Prepare subcontract agreement for execution
DURING the Subcontract Agreement
1. Establish and maintain channels of
communication with subcontractor; perform
on-site visits, if applicable
2. Review and ensure that invoices are:
a. Submitted in a timely manner
b. Expenses are allowable, allocable and
reasonable
c. Expenses are incurred within the period of
performance
d. Expenses are aligned with technical
progress
e. Cost-sharing is appropriately reflected;
if applicable
f. Invoices are approved by PI or their
designee and forwarded to A/P for payment
3. Review technical progress to ensure performance goals are achieved; and identify any
problems in carrying out the project
a. PI is required to fill out a semi-annual
Subcontractor Verification Form
4. If changes occur with the prime or subcontractor; the SP must be notified in order
to amend an agreement
5. Approve close-out
a. PI is required to fill out a Subcontractor
Verification Form
1. Process no cost extensions; when applicable
1. Maintain documentation for monitoring
efforts
2. Process amendments; when applicable
2. Request and review annual A-133 Audit
Reports or audited financials
3. Review A-133 reports or other audited
Financial statements for material
weaknesses, reportable conditions, current
audit findings and prior audit finding
resolutions
a. If a finding is reported and is related to the
project that FAU has subcontracted for,
then General Counsel will be requested to
review to determine if a management
decision is required
4. Issue Management Decision; when applicable
a. Notify PI and SP issued management
decisions, when applicable
5. Assist PI in carrying out their monitoring
responsibilities
a. Issuing semi-annual and close-out
Subcontractor Verification Forms
6. Close-out