Use of subawards
A subaward is a contractual agreement utilized when a portion of work benefitting a Βι¶ΉΣ³» (University) sponsored project is allocated to an external entity, i.e., a subrecipient. The subaward is entered into by the University and the subrecipient and sets forth the terms and conditions for the subrecipient's proposed project work. The subrecipient is generally responsible for complying with the same prime award terms and conditions applicable to the University. A subaward typically includes (but is not limited to) the following:
- Subaward amount for subrecipient's proposed work
- Subaward period of performance (start and end dates for subrecipient work)
- Prime award terms and conditions that are required to be passed down to subrecipient
- Subrecipient's statement of work and corresponding itemized budget
- Payment schedule for subrecipient's project work
- Subrecipient reporting requirements and frequency
Subrecipient vs. contractor
In general, a subrecipient has responsibilities to further the objectives of the sponsored project and to make project related decisions when necessary whereas a contractor has a procurement relationship to the prime award recipient and provides goods and services (per the entity's normal business operations) that are ancillary to sponsored project. To elucidate the differences between a subrecipient and contractor, the table below lists the defining characteristics of each.
Subrecipient
- Carries out a project as opposed to providing goods/services to project
- Performance measured by whether project objectives were met
- Responsible for project related decision making
- Subject to applicable prime award terms and conditions
- Project work performed under a subaward agreement administered by Sponsored Projects
- F&A charged on the first $25,000 of each subrecipient's cost (amount above $25k not charged F&A)
Contractor
- Provides goods/services within normal business operations to many different purchasers and operates in a competitive business environment
- Goods/services provided are ancillary to the operation of the project
- Not subject to prime award terms and conditions
- Goods/services procured under a purchase order issued by the University Purchasing
- F&A charged on the full amount of each contractor's fee
Proposal stage: Subrecipient materials
Determination of a subrecipient typically occurs at the proposal stage. If a subrecipient will be part of a University sponsored project proposal, materials will be required of the subrecipient prior to proposal submission. Materials must include confirmation of sponsor approval when required. The University principal investigator (PI) is responsible for collecting any subrecipient materials and providing them to Sponsored Projects. The materials required of the subrecipient depend upon whether or not they participate in the FDP Expanded Clearinghouse. Therefore, please to see if the subrecipient is a participant.
If the subrecipient participates in the FDP Expanded Clearinghouse, the following materials will need to be provided to Sponsored Projects:
- Subrecipient's statement of work
- Annual and cumulative itemized budget for subrecipent's statement of work and budget justification
- A letter or email from the authorized representative of the subrecipient organization approving the budgets and cost share amounts shown in the proposal
If the subrecipient does not participate in the FDP Expanded Clearinghouse, the following material will need to be provided to Sponsored Projects:
- Subrecipient's statement of work
- Annual and cumulative itemized budget for subrecipent's statement of work and budget justification
- Copy of subrecipient's indirect cost rate agreement if subrecipient's budget includes indirect costs. If subrecipient does not have a negotiated rate agreement, they shall receive the de minimus indirect cost rate of 10% pursuant to the or another rate as negotiated with the subrecipient unless sponsor policy limits the indirect cost rate that can be used in the proposal budget.
- Completed and signed Subrecipient Proposal Assurance Form (SP-Sub-1)
- Any additional materials as required by the sponsor
Award stage: Subaward agreement
Once the University has received and processed the prime award from the sponsor, and the sponsor has approved the subrecipient, the subrecipient's subaward agreement can be issued. Should there be a change in subrecipient materials from what was initially proposed, the new subrecipient materials must be approved by the sponsor before the award can proceed.
A. Cost-reimbursable agreements vs. fixed amount agreements
Cost-reimbursable agreements provide for payment of (as defined in the Uniform Guidance) incurred by the subrecipient to the extent prescribed in the agreement. Most subaward agreements will be cost-reimbursable.
Fixed amount agreements provide for a specific payment amount regardless of the actual costs incurred by the subrecipient under the agreement. Payment may be made in a lump sum at the end of the period of performance or in partial payments upon completion of certain milestones or deliverables. In some cases, fixed amount subawards may be appropriate. In the case of federal awards, fixed amount subawards are permissible only with the prior written approval of the prime sponsoring agency and may not exceed the Simplified Acquisition Threshold (currently $150,000) as long as the agreement satisfies the requirements of the .
If a subrecipient desires a fixed amount subaward agreement, this should be clearly communicated in the proposal so that any necessary approvals may be requested of the sponsoring agency.
B. Subaward agreement forms and other subrecipient information
In order to issue the subaward agreement, the UNR grants and contracts officer will request that the subrecipient complete and return the following forms:
Additionally, the following information may be requested from the subrecipient:
- Indirect Cost Rate Agreement
- Audit Report
C. Subaward agreement execution and issuing of purchase order
After the subaward agreement has been signed by both the University and the subrecipient, the fully executed subaward agreement will be forwarded to the assigned Sponsored Projects grant accountant who will request a purchase order for the amount of the subaward agreement. All subrecipient invoices submitted for payment of project expenses under the subaward agreement will be paid against the purchase order.
Post-award stage: subrecipient invoicing, monitoring, modifications and closeout
With the subaward agreement issued, the day-to-day administration of the subaward includes technical and financial monitoring, subaward modifications and the subaward closeout process. While much of the daily subaward administration is conducted by the Sponsored Projects post-award grant accountants, the University PI has responsibilities as well.
A. Technical monitoring
The subaward agreement will contain the provisions for any progress reports and/or deliverables required of the subrecipient. The University PI is responsible for reviewing subrecipient progress reports and deliverables to ensure their acceptability.
B. Subrecipient invoicing and financial monitoring
The subrecipient shall invoice the University for completed project work as provided for in the subaward agreement. Invoices are sent to the assigned post-award grant accountant who will review claimed expenditures for allowability and compliance with the subaward agreement. After the initial Sponsored Projects review of a subrecipient's invoice, the invoice is forwarded to the University PI for approval. By approving the invoice, the University PI certifies that all necessary progress reports and deliverables have been received and reviewed and that the subrecipient's invoiced expenditures appear to reasonable. Upon receipt of the University PI's approval, Sponsored Projects will forward the invoice to University Accounts Payable for payment.
Additionally, the Sponsored Projects grant accountant routinely monitors and tracks any subrecipient cost share commitment.
C. Subaward modifications
On occasion, the need to modify a subaward agreement due to subrecipient changes in scope of work, personnel, budget, period of performance, etc. may arise. When such need arises, the subrecipient shall communicate the desired modifications to the University PI who will advise the assigned Sponsored Projects grants and contracts officer of the needed changes. Sponsor approval must be obtained. Upon sponsor approval, changes will be made via an amendment to the original subaward agreement, and the purchase order will also be amended if necessary.
D. Subaward closeout
The subaward closeout process includes final financial reconciliation and subrecipient closeout documentation. At the conclusion of the subaward, the Sponsored Projects grant accountant will reconcile the subaward accounting by verifying that all subrecipient invoices have been paid. Any unexpended subrecipient funds that remain encumbered on the University award account will be disencumbered and the purchase order will be closed. Further, the post award grant account will request that the subrecipient complete and return the following forms:
Once the University receives the above completed forms, the subaward is considered closed.