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U.S. Department of Health and Human Services

Postaward Monitoring

Recipients are responsible for managing the day-to-day operations of grant-supported activities using their established controls and policies, as long as they are consistent with HHS requirements. However, to fulfill their role in regard to the stewardship of Federal funds, ASPR monitors their grants to identify potential problems and areas where technical assistance might be necessary. This active monitoring includes:
 
  • Tracking receipt of required financial and progress reports. 
  • Reviewing these reports to identify performance or financial deficiencies.
  • Maintaining records of communications with the recipient.
  • Conducting site visits.
  • Conducting desk reviews of recipient expenditures.
  • Review and resolution of the audit findings.
  • Responding to requests for post award changes to the grant.
Monitoring of a grant will continue for as long as ASPR retains a financial interest in the grant as a result of property accountability, audit, and other requirements that may continue for a period of time after the grant is administratively closed out and ASPR is no longer providing active grant support.
 
Important documents for needed for managing the federal award:
 

Reports

ASPR requires that recipients periodically submit financial and progress reports. Other required reports may include annual invention utilization reports, research misconduct reports, property reports, lobbying disclosures (as required by 45 CFR 93.110(c)), audit reports, reports to the appropriate payment points (in accordance with instructions received from the payment office), and specialized programmatic reports. To learn more, see the section on reporting requirements.
 

Conducting desk reviews of recipient expenditures 

ASPR and the Comptroller General of the United States, or any of their authorized representatives, shall have the right of access to any pertinent books, documents, papers, or other records of grantees and subrecipients which are pertinent to the grant, in order to make audits, examinations, excerpts, and transcripts.  As part of the overall monitoring ASPR’s Division of Grants Management will conduct periodic desk reviews of a grantee’s expenditures.  
 

Post Award Changes

ASPR anticipates that the recipient may need to modify its award budget or other aspects of its approved application during performance to accomplish the award’s programmatic objectives. In general, grantees are allowed a certain degree of latitude to rebudget within and between budget categories to meet unanticipated needs and to make other types of post-award changes. However, in most cases prior written approval is required.  Post award changes may include the following:
    
  • change in approved activities, which may or may not involve a change in scope;
  • change in award terms and conditions, e.g., removing special conditions or imposing a high-risk designation;
  • change in the approved budget, including a change in the overall amount, a change in the type of costs incurred, or a change in the allocation of costs among approved budget categories; and/or,
  • change in award duration, e.g., through a no-cost extension, withholding of support, or a termination action.
For post-award changes that require prior approval:

  • a formal recipient request for approval must be signed or submitted through GrantSolutions by an authorized organizational representative (AOR), PI or Authorized Official, of the recipient and include necessary documentation;
  • the request must be initiated by a recipient 30 days in advance of making the proposed change to allow review and approval or denial of the request. If the recipient implements the change without prior approval and approval is denied, it assumes responsibility for any costs that were not approved and for completing the project as approved;
  • a recipient must obtain approval from ASPR before a subrecipient or contractor under the grant can undertake said activity;
  • the Grants Management Officer (GMO), or his/her designee, is the only ASPR official authorized to approve or disapprove a formal prior-approval request; and
  • a revised Notice of Award (NoA) may be required for some types of post-award changes.
 
Some post award changes that require prior approval are: 
 
  • Change in scope
  • Change in the Principal Investigator or Project Director or other key
  • Change in recipient or performer
  • Changes from the approved budget
  • Deviation from the terms and conditions of the award;
  • Additional time to spend previously awarded funds
  • Carryover of an unobligated balance of federal funds
  See HHS grants policy statement for a detailed list of actions needing prior approval.
 
 

  • This page last reviewed: November 20, 2017