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You are here: Home / Manage subawards with the right level of oversight

Manage subawards with the right level of oversight

Outgoing Subawards · Monitoring Guidance

Manage Subawards with the Right Level of Oversight

The Essentials How Risk Is Determined Risk-Based Actions Compare Risk Levels Document Your Monitoring Who Does What Tools and Resources
Microlearning

Subaward Monitoring

Watch Video  →
Preview of the Subaward Monitoring microlearning video ▶
The Essentials

What Every PI Should Do

Monitoring is more than approving an invoice. Check whether the subrecipient’s work, reports and spending match the agreed scope and schedule, and keep a record of what you reviewed.

Review Progress

Read required technical and financial reports. Compare results with milestones, deliverables and the statement of work.

Review Invoices

Confirm costs appear reasonable and consistent with the approved budget, period and reported progress. Raise questions before approval.

Communicate and Document

Stay in contact, record key decisions and follow up promptly on missing reports, delays or other concerns.

Understand any areas of risk presented by your subcontract and ensure you have a plan for monitoring your subaward that has been communicated with your research admin team so that they can support you. If you are unsure or concerned about any risks, contact your DCG Subcontract Officer to discuss options for mitigating or addressing risk.
Before Monitoring Begins

How to Determine Subaward Risk

Before a subaward is issued, DCG collects and reviews information about the proposed subrecipient and the work it will perform and completes a risk assessment. For subawards, this risk review helps identify if there is any heightened risk where additional monitoring by the PI might be appropriate. DCG communicates with the PI when the assigned risk level is designated as medium or high so that they are aware of any added oversight considerations.

Experience and Performance

Has the organization managed similar awards? Is it new to USC? Have its reports or deliverables arrived on time?

Audit and Financial Information

What do prior audits, available financial statements, accounting systems and internal controls show?

Project Exposure

How much of the prime award is going to the subrecipient, and how much does USC depend on its work to meet project goals?

Other Relevant Circumstances

DCG considers non-U.S. settings and sponsor requirements. For federal awards, USC also checks whether an entity is excluded from receiving funds, including through SAM.gov.

These are factors to consider, not a self-scoring checklist. No single item automatically determines the tier. If you do not have the assigned level or have new concerns, contact your DCG Subaward Officer.

Use the Assigned Risk Level

What Changes as Risk Increases?

Depending on the risk level the PI should consider implementing different practices for ensuring appropriate monitoring of their subaward. Below are some common practices that should be implemented for subawards at different levels of risk. If a PI has a concern they can always reach out to DCG for guidance or to request the addition of terms or requirements to address any concerns.

Standard Monitoring

Low Risk

Possible Indicators

  • Established organization with relevant experience.
  • Strong audit history and documented controls.
  • Timely reports and a straightforward scope.

Recommended PI Actions

  • Review required performance reports, deliverables and invoices against the agreement.
  • Hold routine progress check-ins appropriate to project milestones.
  • Record the review, approvals and any follow-up questions.
  • Tell DCG promptly if performance, reporting or compliance changes.

Enhanced Monitoring

Medium Risk

Possible Indicators

  • New partner or limited similar-award experience.
  • Past reporting delays or remediated audit findings.
  • Significant budget share or more complex work.

Recommended PI Actions

  • Continue all baseline reviews.
  • Agree with DCG on more frequent reports or milestone check-ins, as appropriate.
  • Request expenditure detail or selected supporting documents when warranted.
  • Document check-ins, missed milestones and corrective follow-up.

Intensive Monitoring

High Risk

Possible Indicators

  • Significant unresolved findings or weak controls.
  • Repeated performance or compliance issues.
  • High dependency on critical deliverables.

Recommended PI Actions

  • Continue baseline and relevant enhanced reviews.
  • Reach out to DCG to ensure that your monitoring plan addresses any areas of concern.
  • Use more frequent reports, detailed invoice support, and virtual or on-site reviews when appropriate.
  • Escalate missed milestones, questionable costs or unresolved issues immediately.

Important: A single characteristic does not automatically determine the risk tier. Risk may change when new information arises.

At a Glance

Risk-Based Monitoring Guide

For medium- and high-risk subawards, PIs can work with their DCG Subcontract Officer to include additional and more restrictive terms to address any areas the PI feels might require additional monitoring to ensure subcontractor compliance. In the event the PI chooses not to implement additional terms, the PI will need to ensure their monitoring plan takes any areas of concern into account.

What to Check Low Risk Medium Risk High Risk
Reports and Deliverables Review required reports and progress against milestones. Use more frequent or interim reports where warranted. Agree on closer reporting and corrective milestones.
Invoices and Spending Check costs against the budget, period and progress. Review expenditure detail or selected support. Use detailed support and heightened invoice review as directed.
Communication Hold routine check-ins and record decisions. Increase check-ins; document outcomes and follow-up. Coordinate frequent reviews and prompt escalation.
Additional Oversight Raise concerns when they arise. Discuss a desk review or added conditions with DCG. Consider structured review, special terms and a written monitoring plan.
Evidence to Retain Reports, reviewed invoices and notes. Baseline records plus added reviews and follow-up. Written plan, supporting reviews, corrective actions and decisions.
Illustrative guidance for the meeting. DCG must confirm which actions are recommended, required by agreement, or formally mandated for each tier before publication.
Make Oversight Visible

A Simple Monitoring Plan

It is not only important to ensure that appropriate monitoring is happening but also to document the checks and check-ins that have been in place. There are simple ways to do this to ensure that the PI is ready in the event there is any question as to the monitoring that took place.

1

Plan

Be aware of the level of risk of the subaward, required reports, milestones, invoice checks, check-in schedule and contacts.

2

Review

Note the date, item reviewed, finding, decision and person responsible. Keep supporting reports and communications.

3

Follow Up

Track a concern to resolution. Contact DCG early about delays, questionable costs, compliance or needed agreement changes.

Example entry: “Oct 12: PI had Zoom meeting with subrecipient PI to review progress report.”
Shared Responsibility

Who Does What?

PI

PI and Department

  • Monitor technical progress and deliverables.
  • Review invoices in light of progress and approved scope.
  • Keep monitoring notes and relevant records.
  • Create and adhere to a monitoring plan.
  • Be aware of the risk level of the subaward.
  • Request the addition of terms to mitigate risk.
  • Flag concerns and work with DCG on next steps.
DCG

DCG Subaward Officer

  • Assess subaward risk and communicate high- and medium-risk designations to the PI.
  • Upon PI request, include additional terms to manage risk on high- and medium-risk subawards.
  • Advise the PI on any identified risk and possible ways to mitigate risk.
  • Communicate high- and medium-risk subawards to the sponsor where required.
  • Assist the PI with coordinating a response to any communicated breach of subaward terms.
Continue

Tools and Resources

Below are some tools and guidance to assist you in ensuring that you have a robust plan for monitoring your subcontracts.

Interactive Guidance

USC Research Administration Navigator

Use the RA Navigator by uploading the subaward, identifying any areas of risk or concern, and requesting assistance with generating a subaward monitoring plan for the PI.

Open the RA Navigator  →
One-Page Guidance

PI Risk-Based Subaward Guidance

Thumbnail of the PI Risk-Based Subaward Guidance sheet

Review the complete risk-based guidance for low-, medium-, and high-risk subawards.

View or Download Guidance  →
Microlearning

Subaward Monitoring

Effective management of your outgoing subaward: a short guide for PIs and administrators.

Watch the Video  →
Questions or concerns? Contact your assigned DCG Subaward Officer using the contacts on the Subawards page .
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