New subrecipient invoice approval procedures
The Office of Contracts and Grants (OCG) has implemented new procedures for subrecipient invoice approval and approval delegation.
Beginning in February 2024, CU’s Department of Internal Audit reviewed subagreements active during FY22 and FY23 and subrecipient post-award monitoring practices, implemented at both the department and institution level. Internal Audit’s review was finalized in June of 2024 and the following finding was noted: Financial personnel responsible for supporting subagreement administration do not consistently obtain or retain documentation confirming PI approval or delegation of PI authority for invoice payments.
In response to this finding, OCG has created a new procedure for subrecipient invoice approval and approval delegation.
Important things to note in the procedure:
- Delegation of Approval: If a PI delegates sub invoice approval to another, that delegation approval must be attached to the purchase order. The delegation must be renewed annually.
- Invoice Approval Documentation: Each invoice approval is required to be included on the invoice or attached to the purchase order.
Thank you all for incorporating this into your internal procedures and please feel free to reach out to OCG with any questions.Ìý