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
A Desk Review generally follows these steps:
RFC identifies subrecipients for review based on OSP's risk assessment,
covering all high-risk and subrecipients based on their performance.
RFC reviews the subaward agreement, approved budget, risk assessment,
submitted invoices and other background information for the award.
RFC sends a desk review request to the UNT Health Principal Investigator, who
coordinates with the subrecipient.
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.
RFC requests additional supporting documentation and clarification for any
questioned costs, following up with the PI as needed.
RFC documents its observations, questioned costs, and any recommended corrective actions,
then shares the results with the subrecipient and appropriate UNT Health personnel.
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 appropriate 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 (2CFR 200.334), unless your award terms require longer.
- Respond promptly to request for documentation or clarification, coordinating through
your UNT Health PI.
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 pass-through entity, to monitor subrecipients under the Uniform Guidance (2 CFR
200.331–.333).
