Supporting Documentation for Sponsored Projects (including Incoming Subawards)

Page Updated: July 2nd, 2019

Sponsors (both direct sponsors and pass-through entities) have the ability to request information pertaining to awards that they provide to UW-Madison. They seek access to records to ensure that awards are managed consistent with statutes, regulations, and the terms and conditions of the award. Typically, at UW-Madison, these records or supporting documentation (also called back-up documentation) include screen shots from WISER or copies of vouchers.

The regulation describing the sponsor’s right to access records is 2 CFR 200.336. This includes a right to audit or examine records, as well as timely and reasonable access to personnel to discuss documents. (Audits are coordinated through RSP.)

In addition to the basic right to access documents, sponsors may request documentation as a result of a risk assessment. Federal agencies and pass-through entities are required to perform a risk assessment of applicants or subrecipients. This requirement is described in 2 CFR 200.205 for federal agencies and 2 CFR 200.331 for pass-through entities.

The agency or PTE has some flexibility to decide how to perform a risk assessment and how to use the results of the risk assessment. If either the federal agency or the PTE deem that working with an entity generates a certain level of risk (as determined by the sponsor), the Uniform Guidance allows them to add conditions to the agreement or subaward, per 2 CFR 200.207. If additional conditions are included in an agreement or subaward, it must also describe what action must be taken to enable the conditions to be removed. Among the possible additional conditions is the ability to require the recipient or subrecipient to provide more detailed financial reports.

Sponsors are obligated to monitor awards to ensure that they are being used for authorized purposes, as well as compliant with statutes, regulations, and the terms and conditions of the award. This includes both direct sponsors and pass-through entities who are compelled to review both programmatic and financial information.

There are multiple reasons why a sponsor or PTE may ask for supporting documentation, however, such requests may or may not be reasonable.

• If the request is for UW-Madison to provide supporting documentation on an as-requested basis, that may be acceptable, so long as the requests occur only periodically (e.g., once per project period or once per budget year). Such a request may be part of a sponsor’s routine monitoring or may occur because the sponsor has questions about an invoice they have received.
• If the request is to provide supporting documentation for invoices on a regular, e.g., monthly, basis, that is an unacceptable request and should be questioned. Provision of supporting documentation on a regular basis would create significant burden for UW-Madison and should not be included as a term and condition of the award.
• In the event that an award requires supporting documentation, departments must provide this information to the RSP accountant for submission to the sponsor.

For questions regarding supporting documentation that arise during the Pre-Award process, please work with RSP Pre-Award staff assigned to the award. For questions that arise during award management or closeout, please work with the RSP Post-Award accountant. For audit related questions, please contact the RSP Audit Coordinator.