1Assess risk before and during the subaward
Risk factors may include experience, systems, audit results, financial stability, prior performance, location, complexity, key personnel, data, security, and the significance of the subaward.
The assessment should lead to proportionate actions such as more frequent reporting, technical assistance, special terms, or closer invoice review.
2Monitor programmatic and financial performance together
Review progress reports, deliverables, invoices, cost detail where required, budget status, compliance information, and communication from the principal investigator. A clean invoice does not prove that the scope is on track.
Document follow-up and unresolved items so monitoring survives staff turnover.
3Close and retain the subaward record
Confirm final deliverables, invoices, required reports, property, inventions, data, and other obligations. Resolve questioned costs and open commitments before the prime award closes.
The pass-through entity should keep the risk assessment, agreement, monitoring, communications, and closeout evidence together.