Desk Review
Desk Review
A desk review is a remote (off-site) examination of a subrecipient's financial and programmatic performance. Research Financial Compliance (RFC) uses a consistent, risk-based desk review process to confirm that subaward's invoiced expense comply with the Uniform Guidance (2 CFR 200), award terms and UNT Health policy.
Desk reviews are conducted for all high-risk subrecipients and selected medium-risk subrecipients, based on the risk assessment the Office of Sponsored Programs (OSP) assigns. The scope of a desk review may cover a single award period or span multiple periods, as the reviewer determines appropriate.
A. Purpose of a Desk Review
A Desk Review is designed to:
♦ Verify costs are allowable, allocable, reasonable, consistently treated and within
the period of performance
♦ Confirm adherence to the approved budget
♦ Assess and document the subrecipient's risk and internal controls
♦ Identify observations and questioned costs
♦ Recommend corrective actions where needed
B. The Desk Review Process
A desk review generally follows these steps:
1) Selection
RFC identifies subrecipients for review based on OSP's risk assessment, covering all
high-risk and selected subrecipients.
2) Background Review
RFC reviews the subaward agreement, approved budget, risk assessment, submitted invoices,
and other background information for the award.
3) Request to the PI
RFC sends a desk review request to the subrecipient's Principal Investigator (PI)
and their subrecipient invoice contact.
4) Examination of Expenditures and Controls
RFC reviews expenditures for compliance with federal, state, and institutional requirements.
If the subrecipient's internal controls are not clear, RFC follows up with the PI
to understand the subrecipient's processes and procedures.
5) Follow-up on Questioned Costs
RFC requests additional supporting documentation and clarification for any questioned
costs, following up with the PI as needed.
6) Reports and Recommendations
RFC documents its observations, questioned costs, and any recommended corrective actions,
then shares the results with the subrecipient and appropriate UNT Health personnel.
C. How to Prepare for a Desk Review
Subrecipients who maintain organized records throughout the award can respond to a desk review quickly and with minimal disruption. To prepare:
♦ Keep accounting records that trace to source documentation. Each invoiced cost
should tie back to receipts, payroll records, or other support in your system of record.
♦ Have supporting documentation ready, such as paid receipts, payroll registers and
effort certifications, travel logs and hotel folios, and vendor contracts and invoices.
♦ Confirm costs align with the approved budget and fall within the period of performance.
♦ Verify F&A and fringe were applied at the approved rates, and that any mandatory
cost sharing is documented.
♦ Maintain written internal controls, policies, and procedures, and be ready to describe
how your organization administers the subaward.
♦ Retain award records for at least three years from the date the final financial
report is submitted (2 CFR 200.334), unless your award terms require longer.
♦ Respond promptly to requests for documentation or clarification, coordinating through
your UNT Health PI.
D. Results of the Desk Review
At the conclusion of the review, RFC documents its observations, any questioned costs,
and recommended corrective actions. Results of the desk review are discussed with
the subrecipient's principal investigator and/or institutional leadership.
Where corrective action is recommended, RFC works with the subrecipient and the UNT
Health PI to resolve the findings. Questioned costs may require additional documentation,
and amounts determined to be unallowable may need to be removed or returned. These
steps support UNT Health's responsibility, as a passthrough entity, to monitor subrecipients
under the Uniform Guidance (2 CFR 200.331–.333).
Contact
For questions and concerns about UNT Health's subrecipient desk reviews, please contact: RFCSubMgmt@unthealth.edu