A subaward is an agreement with an eligible organization performing a portion of an SIBCR research project or program. The terms of the relationship are influenced by the prime agreement and all subawards must be monitored to ensure that the subrecipient complies with these terms. A subrecipient works collaboratively with the prime award recipient to carry out the scope of work.
Federal regulations for subrecipient monitoring are found in OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR §200) ("Uniform Guidance"), sections §200.330 and §200.331.
SUBRECIPIENT VS. CONTRACTOR DETERMINATION
If another entity is involved in carrying out a sponsored project, it does not automatically imply that a true subrecipient relationship exists. Since it is sometimes difficult to tell the difference between a subrecipient and a contractor, it is easy to confuse the two.
If the work constitutes a contract, indirect costs will need to be charged on the entire amount of the transaction.
A comparison of the components of a subaward versus a contract can be found here on the Subaward vs. Contractor Checklist.
If it is determined that a contractual relationship exists, the SIBCR Purchasing Cost Thresholds will apply and a vendor agreement will be issued in lieu of a subaward.
SUBAWARD FORMS AND TEMPLATES
The stages of the subaward process are in order below with the requisite forms and templates for each stage.
The SIBCR PI works with the collaborating PI of the project to develop a work plan and a budget. The subrecipient PI or designee is responsible for ensuring that sign-off is obtained from the collaborating institution prior to SIBCR approval and submission to the sponsor. SIBCR and the SIBCR PI collaborate to submit the proposal to the sponsor in a timely manner and facilitate communication between the parties. The Subrecipient Proposal Checklist includes proposal information and a required documents list.
The Subrecipient Commitment Form was designed to collect information about the subrecipient at the proposal stage. It is used to verify information about the subrecipient contained in the proposal and to determine if the other organization’s role is that of a true subrecipient. Collecting this information at the proposal stage allows the process of establishing a subaward to move forward more quickly at the award stage.
The completed and signed Subrecipient Commitment Form must be received before a subaward will be established. The form is considered valid if the subrecipient’s authorized representative has signed the form within the past year.
Once the sponsor sends the award notice, SIBCR administration initiates the process of establishing a subaward by emailing the subaward documents to the administrative contact at the collaborating institution. SIBCR obtains any required regulatory compliance or financial audit documents not already on file from the subrecipient.
An amendment is required if there is a significant change to a subaward. A significant change is defined by the sponsor. Some examples of when we use a modification include, but are not limited to the following situations: to document a change in key personnel or reduction in effort of key personnel equal to or greater than 25%, for increases or decreases to award amounts and for early terminations or no-cost extensions.
Final reports are required of the subrecipient. Sponsor specific closeout requirements are included as part of the terms and conditions in the SIBCR subaward.
SIBCR AS A SUBRECIPIENT
SIBCR views subawards similar to grant awards in regards to proposal submissions, fiscal monitoring and reporting requirements. The grants administrator plays a pivotal role in negotiating terms and conditions of subawards with the prime grant recipient and serving as a liaison between the PI and the prime awardee for administrative matters. SIBCR accounting staff prepares bills for subawards and monitors accounts receivable. SIBCR grant administrators follow-up with the PI and/or staff as necessary.
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