Sponsored Project Subawards and Subrecipient Monitoring
Policy number: 10.8
Policy section: Research
Revised Date: December 16, 2019
Definitions of capitalized terms are set forth in Appendix A.
2. Policy Statement
As a condition of accepting Funding from a Sponsor, the University is obligated in its role as primary recipient to comply with federal, state, and local regulations. If the University makes a Subaward to assign responsibility for conducting a portion of the work required by an Award to a Subrecipient, the University remains responsible to the Sponsor for managing Funding and meeting performance goals. Thus, the monitoring of technical and financial activities associated with a Subrecipient is an integral part of the University’s stewardship of Funding.
3. Scope of this Policy
This policy does not apply to consultant agreements or to agreements for the procurement of goods or services from vendors who not responsible for carrying out any portion of the University’s programmatic Effort under a Sponsored Project.
4. Subaward Requirements
All Subawards must be written documents, negotiated by the Office of Research and Graduate Studies and must document the terms of the Subrecipient's responsibilities regarding:
- cost accounting systems;
- maximum amount of Funding committed;
- property management, when applicable;
- technical performance;
- period of performance;
- certifications of status under and compliance with the Award; and
5. Roles and Responsibilities: Principal Investigator/Project Directors
- Principal Investigators/Project Directors in collaboration with the Office of Research and Graduate Studies and the Office of Grant and Contract Accounting will monitor the programmatic and financial activities of Subrecipients to confirm:
- proper stewardship of funds; and
- attainment of performance goals (scope of work or specific aims).
- The Principal Investigator/Project Director must follow University procedures for monitoring Subrecipient compliance during the period of performance of the Subaward and during Subaward Closeout Principal Investigator/Project Director is responsible for determining the need for a Subaward and providing justification for selection of the Subrecipient. The Principal Investigator/Project Director’s original Proposal must include a separate Statement of Work and line-item budget for each proposed Subaward.
- The Principal Investigator/Project Director is responsible for monitoring the progress of Subrecipients’ scope of work. This process includes a combination of informal progress reports via phone conversations and/or face-to-face discussions, as documented by recordings in a journal or other written summaries; e-mail communications; and/or more formal technical reports or other deliverables due on specific dates. Technical progress reviews and acceptance are documented by the Principal Investigator/Project Director’s signature on invoices received from the Subrecipient.
- When the Principal Investigator/Project Director has an interest in or a relationship with the Subrecipient entity, it shall be managed as required by University Policy 1.3, Conflict of Interest and/or University Policy 10.7, Financial Conflicts of Interest in Externally Funded Research, as applicable.
- It is the responsibility of the Office of Research and Graduate Studies to review proposals prior to submission to assure that Subaward arrangements are appropriately budgeted in the prime Award.
- The Office of Research and Graduate Studies will prepare the final Subaward with all attachments. Prior to the Subaward being issued, a risk assessment will be performed. The Office of Research and Graduate Studies will ensure that agreements executed with Subrecipients are accurate, complete, and compliant with the prime Award. When the Subaward involves federal Funding, The Office of Research and Graduate Studies will:
- check the list of debarred and suspended (excluded) parties, at SAM.gov or successor website, to ensure that the Subrecipient is eligible to receive federal contracts or assistance;
- ensure that the Subrecipient meets Federal audit requirements; and
- ensure there are provisions that the Subrecipient has a property control system that is either federally approved or meets federal property regulations, unless exempted by special terms and conditions.
- The Office of Research and Graduate Studies will append Subrecipient compliance reports to the Sponsored Project’s administrative file.
6. Roles and Responsibilities: The Office of Research and Graduate Studies
The Office of Research and Graduate Studies will verify and document, with appropriate evidence, a Subrecipient's compliance:
- when Subawards are executed;
- prior to payment of each invoice; and
- at the Subaward Closeout of all Subawards.
7. Roles and Responsibilities: Grant and Contract Accounting
- Invoices presented to Grant and Contract Accounting for payment under Subawards must be signed by the Principal Investigator/Project Director attesting that the stipulated Sponsored Project scope of work is being (or has been) completed according to specifications and schedules in the Subaward Statement of Work, and by the Assistant Vice President for Research Integrity and Operations attesting to satisfactory review of the Subrecipient's compliance with audit, administrative, and regulatory terms in the Subaward.
- Grant and Contract Accounting will perform a secondary review of all approved invoices to ensure they meet budgetary restrictions. When necessary, additional documentation may be requested from the Subrecipient to ensure unallowable costs do not exist. Such documentation may include, but is not limited to, the following:
- Payroll records;
- Copies of paid invoices;
- Descriptions of services performed; and/or
- Travel documentation.
- Copies of signed invoices shall be included in the Sponsored Project's accounting file.
8. Closeout of Subrecipient Awards
- The Office of Research and Graduate Studies must begin Subaward Closeout actions immediately following conclusion of the Subaward period of performance. Subaward Closeout requirements must include:
- Receipt of final invoice;
- Collection of all required deliverables (technical/progress reports, patent/invention documentation, equipment reports, etc.) to be provided by the Subrecipient and final verification of technical completion by the Principal Investigator/Project Director, indicated by the Principal Investigator/Project Director’s signature and date on the final invoice; and
- Completion of any necessary final review of costs charged to the University by the Subrecipient and final Subaward Closeout of all commitments, accrued costs, or payables.
- During the Subaward Closeout process for a Subaward, the Office of Research and Graduate Studies and the Principal Investigator/Project Director will adhere to the Award Closeout requirements of the Award under which the Subaward was issued. In general, a Subaward is closed when it has expired and/or when final technical deliverables are received and financial matters are concluded.
9. Related Policies and Documents
- University Policy 1.3, Conflict of Interest
- University Policy 10.1, Sponsored Research and Activities
- University Policy 10.7, Financial Conflicts of Interest in Externally Sponsored Research
- Research Handbook
Appendix A: Definitions
"Award" means a Grant, subgrant, Contract, subcontract, or Cooperative Agreement that provides for Funding.
“Award Closeout” is the process of documenting and assuring the fulfillment of the terms and conditions of the Award, of certifying University compliance with applicable regulations and making final disposition of all Award by-products, such as final vouchers, reports, patent disclosures, property inventory, and the collection of outstanding accounts receivable and addressing deficit or residual balances.
"Contract" means a legally enforceable agreement between the University and a Sponsor that provides Funding when a primary purpose is delivery to the Sponsor of property or services for the benefit of the Sponsor, in addition to the research, educational, or service benefit to the University.
"Cooperative Agreement" means a legally enforceable agreement between the University and a Sponsor that provides Funding when substantial interaction between the Sponsor and the University is anticipated during the performance of the Sponsored Project.
“Effort” means the time spent on Sponsored Projects and all other activities for which an individual is compensated by the University. See University Policy 10.15, Sponsored Project Effort Reporting.
"Grant" means a legally enforceable agreement between the University and a Sponsor that provides Funding when:
- the Sponsor has no expectation of delivery of a specific product or service other than a final written report;
- no substantial interaction between the Sponsor and the University during performance is anticipated; and
- the agreement contains general terms and conditions that stipulate a period of performance and minimal reporting requirements.
“Funding” means financial support for a Sponsored Project, including money, property, services, or anything of value in lieu of money.
"Principal Investigator/Project Director” means the individual solely responsible for technical conduct of a Sponsored Project, technical contact with the Sponsor, expenditure of Sponsored Project Funding, and fulfillment of technical performance and reporting obligations under an Award. "Principal Investigator” (PI) includes an individual designated in an Award as "Project Director" (PD), when performing the functions of a Principal Investigator, or other individuals performing the functions of a Principal Investigator. For the period of the Award, the Principal Investigator/Project Director must be a full-time employee (staff, tenured or, tenure track faculty, Research Professor, Research Associate Professor, Research Assistant Professor, or, if approved by the Provost or his or her designee, a non-tenure track, non-tenure eligible faculty member) appointed pursuant to University Policy 2.3, Faculty Ranks, Academic Titles, and Voting Rights.
“Proposal” means the document submitted to a Sponsor requesting Funding for a Sponsored Project which includes, without limitation, (i) Financial Obligations, Regulatory Obligations, Reporting Obligations or Accounting Obligations, as described under “Sponsored Projects”, (ii) a Statement of Work and (iii) a budget.
“Research Handbook” refers to the document maintained by the Office of Research and Graduate Studies specifying current procedures and requirements for the proposal, acceptance, execution, and oversight of Sponsored Projects.
"Sponsor” means any external entity that provides Funding to the University. Sponsors may be (i) governmental agencies (for example, federal, state, or local governments or their administrative organizations); (ii) nonprofit organizations (for example, universities, nonprofit corporations, foundations, or associations); (iii) for profit organizations (for example, corporations, partnerships, sole proprietorships, and other business entities); or (iv) individuals.
"Sponsored Projects” means all projects, programs, research, training, public service and other activities that receive external Funding through Grants to the University or through Contracts or Cooperative Agreements between the University and a Sponsor, where one or more of the following obligations applies:
- Financial Obligation. The University is required to comply with conditions imposed when a Sponsor awards Funding for the performance of services or delivery of products described in a Statement of Work;
- Regulatory Obligation. The University is required to comply with Sponsor regulations.
- Reporting Obligation. The University is required to provide to the Sponsor technical performance reports or regulatory or administrative reports; or
- Accounting Obligation. The University is required to establish a separate accounting record of Sponsored Project expenditures to demonstrate allowability of costs, to maintain financial accountability, to make financial reports to the Sponsor, and to preserve appropriate records for audit.
“Statement of Work” means the component of a Proposal or an Award that describes the specific work to be undertaken and the products that will be produced by the Sponsored Project. In the case of a Subaward, “Statement of Work” describes the specific work to be undertaken and the products that will be produced by the Subrecipient.
“Subaward” (also referred to as subgrant if the prime award is a Grant, subcontract if the prime award is a Contract or subagreement) means a formal, secondary agreement between the University and a qualified organization for the performance of a substantive portion of the program funded under an Award. The term also includes subawards made by a Subrecipient to a lower tier Subrecipient.
“Subaward Closeout” is the process of documenting and assuring the fulfillment of the terms and conditions of the Subaward, of certifying Subrecipient compliance with applicable regulations and making final disposition of all Subaward by-products, such as final vouchers, reports, patent disclosures and property inventory, and the collection of outstanding accounts receivable and addressing deficit or residual balances.
“Subrecipient” means the legal entity to which a Subaward is made and which is accountable to the University for the use of the Funding provided in carrying out a portion of the University’s programmatic Effort under a Sponsored Project. The term may include institutions of higher education, other non-profit organizations, for-profit organizations and foreign or international organizations (such as agencies of the United Nations), if approved by the Sponsor.
“University Policies” means, for the purposes of this policy, all University Policies included in the University Policy Manual and all other procedures, guidelines, and requirements of the Office of Research and Graduate Studies and the Office of Grant and Contract Accounting included in the Research Handbook, and the procedures, guidelines, and requirements of all University colleges, schools, departments, centers, institutes, and divisions.
Revised: December 16, 2019
Adopted: January 15, 2015