Review a subrecipient invoice and choose the next monitoring step

What you will practice

• Distinguish invoice review from the broader duty to monitor a subrecipient.
• Identify duplicate, unsupported, or incorrectly allocated charges without assuming every discrepancy is fraud.
• Document a proportionate follow-up plan while respecting payment requirements.

Educational pilot for a domestic, cost-reimbursement subaward to a private nonprofit under a Federal assistance award applying the 2024 Uniform Guidance revisions. All organizations, invoice details, rates, and procedures in the exercise are fictional. Check the applicable award, agency policy, and subaward before using this workflow. The time estimate is for planning; this unit does not award CE credit or approved contact hours.

Start with the agreement

Confirm the documented subrecipient determination under §200.331: the organization carries out part of the Federal program rather than selling routine goods or services. NSF's Subrecipient Management Resources explains these characteristics. This exercise assumes that determination is already documented.

Check the subaward and amendments for funding, dates, scope, reporting, rate and base, and payment terms. Section 200.332(b) requires communicating applicable requirements. For an NIH example, Grants Policy Statement §15.2.1 requires the written agreement to address reimbursement procedures and supporting documentation. There is no universal invoice template for every sponsor.

First identify the payment arrangement. Section 200.333 separately governs fixed amount subawards; their payment conditions cannot simply be replaced with the actual-cost review used here.

Review the dollars and the work

Reconcile charges, prior billings, credits, and cumulative funding. Check dates, required certifications, scope, rate, base, and restrictions. Section 200.403 requires adequate documentation and other allowability criteria; budget inclusion alone does not establish allowability.

Ask what benefit the project received. Under §200.405, shared costs follow the supported allocation of benefits. Available budget does not justify assigning another project's share to this subaward. Request focused support when a charge is unclear, using secure channels for sensitive records.

Read the performance information alongside the invoice. Section 200.332(e) requires financial and performance report review and follow-up on significant adverse developments. Slower progress may call for explanation or corrective action; it does not automatically make every salary charge unallowable. Record what the financial reviewer and project lead actually checked.

Make the response proportionate

Invoice approval is one monitoring activity, not an audit opinion. Section 200.332(c) calls for assessment of fraud and noncompliance risk, considering experience, audits, personnel or system changes, and Federal monitoring. A clean prior audit does not erase a new duplicate-billing pattern. Under §200.501(e), being below the Federal audit threshold also does not remove access to records or the pass-through entity's monitoring duties.

Choose a response linked to the issue: training, targeted supporting records, a progress discussion, or another justified monitoring tool. Section 200.332(f) lists possible tools, not a mandatory site visit for every subrecipient. Document the issue, owner, evidence needed, next review date, and resolution. Section 200.303 supports documented controls and prompt action on identified noncompliance.

Review promptly. For non-State recipients and subrecipients using reimbursement, §200.305(b)(3) requires payment within 30 calendar days after receipt unless the request is reasonably believed improper. Paragraphs (b)(6)-(7) restrict withholding allowable-cost payments. Follow applicable agency and agreement procedures to resolve disputed amounts; do not invent a blanket right to freeze all payments until an audit.

Fictional invoice: Alder University and Pine Research Institute

Alder has issued Pine, a private nonprofit, a $200,000 subaward. Pine requested reimbursement as its payment method. August is within the approved budget period. Prior accepted invoices total $150,000. The fictional agreement uses a negotiated 60% indirect rate on salary and wages only; this is an exercise assumption, not a recommended rate or universal base.

Pine requests $17,600: $9,000 salaries, $2,400 shared supplies, $800 travel, and $5,400 indirect costs. Salary support is adequate. A usage log assigns 40% of the supplies to this project. The same $800 travel charge was included in a previously paid invoice. All other allowability criteria are satisfied for this exercise.

The latest required performance report shows 40 interviews completed against a target of 60 by that reporting date. Pine has a new grants accountant; its last audit had no findings. Complete the worksheet, calculate the corrected request, and choose a focused follow-up. These are review signals, not proof of fraud.

Sources and applicability

Check the terms, policy dates and agreements that apply to your award. These fictional practice cases do not authorize an institutional transaction.

1. 2 CFR 200.332: Requirements for pass-through entities · Checked 2026-09-17
2. 2 CFR 200.303: Internal controls · Checked 2026-09-17
3. 2 CFR Part 200 Subpart E: Sections 200.403 and 200.405, allowability and allocability · Checked 2026-09-17
4. 2 CFR 200.305: Federal payment · Checked 2026-09-17
5. 2 CFR 200.333: Fixed amount subawards · Checked 2026-09-17
6. 2 CFR Part 200 Subpart F: Section 200.501, audit requirements and exemptions · Checked 2026-09-17
7. NSF Subrecipient Management Resources: Subaward and contract determinations · Checked 2026-09-17
8. NIH Grants Policy Statement, March 2026, section 15.2.1: Written Agreement · Checked 2026-09-17