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GAP 200.285, Subrecipient Invoicing: Late Final Invoices
Procedure:
GAP 200.285, Subrecipient Invoicing: Late Final Invoices
Related Materials:
GAP 200.180 Closeout of Sponsored Projects
Effective Date:
September 2015
Last Review
July 2023
Revision History:
June 2016
July 2021
I. General
II. Terms and Conditions: Final Invoice Due Dates
III. Processing Late Invoices
I. General
A subrecipient (subcontractor or subawardee) is an external organization that receives funding from Duke to collaborate in carrying out sponsored programs.
Duke University is responsible for reimbursing the subrecipient in accordance with the terms and conditions of the subaward agreement and the subrecipient is responsible for submitting deliverables in accordance with the terms and conditions of the subaward agreement, including submitting its final invoice, marked as such, by the deadline designated in the subaward agreement.
The following guidelines and procedures are provided to address institutional responsibilities of the PI and Grant Manager when a subrecipient submits a late invoice. A late invoice is defined as an invoice that is received after the due date specified in the subaward agreement.
II. Terms and Conditions: Final Invoices Due Dates
As a member of the Federal Demonstration Partnership (FDP), Duke University has agreed to adhere to the processes and procedures established by the Committee on Subrecipients and use the FDP subaaward templates when they are appropriate. On a standard federal grant, the FDP template provides 60 days after the end date of a subaward agreement for the subrecipient to submit a final invoice. This in turn allows Duke sufficient time to fulfill its reporting requirements to the prime sponsor.
Based on the terms and conditions of Duke’s prime awards when FDP does not apply, the pre-award offices may need to shorten or lengthen the due date for a subrecipient final invoice in order to comply with the sponsor requirements for Duke’s final reporting.
III. Processing Late Invoices
It is anticipated that most if not all subrecipient invoices will be sent directly to the Office of Post-Award Administration (OPAA) for processing. If the department receives an invoice from the subrecipient, it must forward to the OPAA Subaward Team at ospsubcontractmgmt@duke.edu. OPAA will create an Accounts Payable Check Request (eCR) which will route electronically to the Duke unit responsible for approving the Check Request.
When a final invoice is received after the due date, the owning Duke unit has the responsibility for determining whether to approve the eCR initiated by OPAA for payment or to reject it unpaid. If the owning Duke unit approves payment, Duke University will pay the invoice and the owning unit will incorporate the charge into its closeout documents appropriately (See GAP 200.180, Closeout of Sponsored Project).
By approving payment for a late subrecipient invoice, the owning Duke unit then assumes the responsibility of covering any costs that the sponsor deems unreimbursable under the terms of Duke’s award. If the Sponsor refuses to reimburse the invoice, any unreimbursed costs will be written off to the WBSE’s backstop code by OPAA.