Federal funding agencies require that institutions working on subawards under Harvard prime awards follow all of the rules and regulations that would apply if the award had been issued to them directly. Further, the responsibility for monitoring compliance with those regulations devolves to Harvard as holder of the prime award. The Harvard subrecipient monitoring policy provides guidelines for this process. OSP has developed a Policy and Monitoring Guide along with training opportunities.
The policy mandates two kinds of monitoring: (1) making sure that the subrecipient institution complies with the auditing requirements of OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) (“Uniform Guidance”), specifically §200.331, and (2) making sure that the subrecipient unit at that institution is managing the subaward correctly. It is the PI’s responsibility to carry out the second part of the policy, principally by:
- Routinely gathering and reviewing Technical Performance Reports
- Routinely reviewing invoices and expenses relative to budget
- Conducting periodic on-site visits, when necessary
- Initiating audits, when necessary