Subawards and Subrecipients

Subrecipient Monitoring Policy

Subrecipient Monitoring Policy 4009 applies to all subawards issued under sponsored projects awarded to Mason.  A subaward transfers a portion of the research or substantive effort of the prime award to another institution or organization.

Mason is responsible for financial and programmatic monitoring of sponsored project funds awarded to Mason that are subcontracted to another institution or organization (subrecipient). To provide the monitoring required by federal regulations and to ensure good stewardship of sponsored projects, Mason will use reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers awards in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. The Subrecipient Management and Monitoring Procedure Guidelines provide detailed information regarding the tasks involved in implementation of the Subrecipient Monitoring Policy.

Mason’s Subrecipient Determination Tool is also a useful resource for making these determinations.

Uniform Guidance provides subrecipient and contractor determinations for outside entities.


  • Advises and provides to subrecipients copies of federal laws or regulations, terms and conditions of the prime award or agreement, and Mason requirements that apply to the subaward or subcontract.
  • Provides subrecipients with information regarding the prime award including Catalog of Federal Domestic Assistance number (CFDA), title, award name and number, award dates, and funding agency, as required by OMB Uniform Guidance, 2 C.F.R. Part 200.”
  • Monitors costs and activities of subrecipients to ensure expenditures charged to Mason are consistent with the budget and scope of work of the subaward or subcontract. Ensures that the performance goals set forth in the scope of work are being met in a timely manner.
  • Conducts an annual risk assessment of all active subcontracts or subawards to determine which subrecipients require closer scrutiny.
  • Ensures that subrecipients expending $750,000 or more in federal awards during the subrecipient’s fiscal year have met the audit requirements of OMB Uniform Guidance for that fiscal year.”
  • Issues management decisions on audit findings within six months after receipt of the subrecipient’s audit report and ensures that the subrecipient takes appropriate and timely corrective action.
  • Considers whether subrecipient audit findings necessitate adjustment of Mason’s records, such as budget modifications or reallocation of resources, a demand for repayment from the subrecipient, or other remedial measures.
  • Requires each subrecipient to permit the sponsor and/or Mason and its auditors to have access to the subrecipient’s pertinent records and financial statements, as necessary.

Required Process:

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Effective November 6, 2019, all subcontract invoices received for subawards on sponsored projects will be routed for approval through the banner workflow system.

  • All subaward Invoices are sent to Accounts Payable (AP) by the subrecipient.
  • AP logs the invoice and initiates the workflow transaction to route the invoice to OSP through banner workflow.
  • OSP will complete their initial review of the invoice to ensure sufficient funding is available and the invoicing period is within the approved period of performance.
  • OSP will then route the invoice to the Principal Investigator (PI) for approval through the workflow system.  The PI must log in to the workflow system to review and approve the invoice. Upon completion of this step the invoice will route back to AP to process the payment to the subrecipient.

Please note, when off campus or using a wireless campus connection, you must first connect to Mason’s VPN in order to access the workflow.