Monitoring Funds and Activities of Subrecipients

The University and the PI/PD are responsible for insuring that subcontractors meet all the federal and state regulations imposed upon Appalachian.

If Appalachian receives a grant that includes subrecipients, the University and the Principal Investigator (PI)/Project Director (PD) are responsible for insuring that the subrecipients meet all the federal and state regulations imposed upon Appalachian. This section describes what steps should be taken to monitor our subrecipients (which is called subrecipient monitoring).

Under reporting requirements mandated by the Federal Funding Accountability and Transparency Act (FFATA), Appalachian must now verify that all subrecipients and vendors paid a cumulative amount of $25,000 or more in federal funds have both a:
  • Valid CCR registration (Central Contract Registration);
  • DUNS number (Dun and Bradstreet Universal Numbering System). 
    Please note: The University cannot issue a subrecipient agreement or purchase order until these requirements are met. Effective October 1, 2010, a DUNS number and CCR CAGE Code (a 5-digit federally assigned identifier) are required at the point of proposal submission.
  • Once the subrecipient agreement has been fully executed (i.e., authorized officials for all parties have signed the agreement), the responsibility for insuring that all subrecipient expectations are met belongs to you, the PI/PD.
Your contact person in Special Funds Accounting will assist you with monitoring subrecipient compliance. This is done in several ways:
  • Reviewing invoices to insure they match the proposal budget and the scope of work 
  • Reviewing all cost share documentation to insure it meets the federal, state, and University guidelines 
  • Conducting site visits as necessary 
  • You will be responsible for approving all work completed by a subrecipient before payment is made to them.
  • You will collect all technical reports from the subrecipient as required by the subrecipient agreement. These should be posted to AGrants as part of the project record.


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