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Subaward (outgoing)

A subaward (also known as a subagreement or subcontract) is an agreement issued by the University of North Florida under its Prime Award to another organization, setting forth the terms and conditions whereby the subrecipient will assist UNF by performing a significant programmatic aspect of the overall project. The subaward process begins when a grant, cooperative agreement, or contract is issued to UNF from a sponsor for the purpose of completing a project/research study within a certain period of time with a set amount of funding ("Prime Award").

  • The Federal Uniform Guidance, 2 CFR 200.330 distinguishes between a contractor for goods or services and a subrecipient.
  • The Principal Investigator should complete the Checklist to Determine Subrecipient or Contractor Classification and/or consult with the Research Development team to assist in determining the need for a subaward versus a contractor for a sponsored project.
    • A subaward is used when a substantive portion of the programmatic work outlined in an UNF proposal is conducted at another organization.
      • Often, the other organization is another education or research institution, but can be any organization outside the University, domestic or foreign.
            
     
  • Subawards do not include payments for procurement of goods or services to a contractor or payments to an individual that is a beneficiary of a Federal program.

Issuance of a Subaward

  • After an award is received by the Prime Sponsor, the issuance of a subaward begins with the completion of the Request for Subaward/Subcontract form by the Principal Investigator.
    • Documentation required to issue a subaward includes the following:
      1. Letter of intent
      2. Budget
      3. Budget Narrative
      4. Scope of Work
       
     
  • Subrecipients on federal funding projects will be required to complete a Subrecipient Information and Compliance form.
  • The Contract Administration unit will issue a subaward to a subrecipient.
  • The issuance of a subaward takes about five to ten business days; however, this process may take longer if additional information is required by the subrecipient or terms and conditions on the subagreement must be negotiated between parties.
  • Only those persons authorized to sign grants and contracts can provide a legal binding signature for a subaward agreement.
  • Most of the primary award terms and conditions will flow through to the subrecipient, particularly the regulatory requirements and obligations.

Relationship Between Prime Sponsor, Pass-Through Entity and Subrecipient

sponsor relationships

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Prime Sponsor

Ex. (NIH, NSF, DOE, etc.)

  • Accountable to board, Congress
  • Provides source of funding
  • Establishes terms and conditions
  • Establishes due dates

Prime Sponsor works with Pass-Through Entity

Pass-Through Entity

Ex. (University of North Florida)

  • Accountable to sponsor
  • Recipient of funding, reports, expenitures to prime sponsor
  • Adheres to sponsor terms and conditions
  • Oversees subrecipient
  • Sets subrecipient reporting requirements and due dates

Pass-Through Entity works with Subrecipient

Subrecipient

Ex. (Institution of higher education, company, etc.)

Relationship Between Prime Sponsor, Pass-Through Entity and Subrecipient
  • Accountable to pass-through agency
  • Subrecipient of funding, reports expenses to pass-through entity
  • Adheres to subaward terms and conditions
  • Reports progress to pass-through entity

Incoming Subawards

An incoming subaward is when another institution or agency (pass-through entity) receives funding and issues a subaward to UNF (subrecipient) for a portion of the project.

  1. a. Each agency may require specific information from UNF to enter into a subaward agreement. Such information may include, but is not limited to, a letter of intent, budget, budget narrative, certifications, assurances, compliance form, and a scope of work.
  2. b. ORSP will collaborate with the Principal Investigator to provide the necessary documents required for an incoming subaward.

Subrecipient Risk Assessment

The Federal Uniform Guidance 2 CFR 200.331b requires UNF to "evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring."

 

When the University of North Florida receives sponsored funding, it accepts the obligation to oversee work being performed by subrecipients in accordance to the Federal Uniform Guidance, 2 CR 200.331.

 

The Contract Administration unit performs a Subrecipient Risk Assessment on subrecipients on federal and federal pass-through sponsored projects.

 

This risk assessment includes a questionnaire of the subrecipient's financial systems, prior experience with similar awards, past audit activity, and internal controls.

 

When necessary, UNF will impose limitations and requirements on the subrecipient through subaward terms and conditions per Federal Uniform Guidance, 2 CFR 200.521.

Subrecipient Monitoring

Subrecipient monitoring enables the University of North Florida to review scientific progress, expense allocation, and confirm that the subrecipient is performing according to the Principal Investigator's programmatic needs.

 

Subrecipient monitoring includes the following tasks and responsibilities:

 

Responsibilities for Subrecipient Monitoring
TASKS PI ORSP
Collects, reviews, and retains subrecipient's technical/performance reports as required by the terms of the subaward. Yes -
Monitor subrecipient adherence to terms and conditions of the contract Yes -
Ensure that all required reports are received by the subrecipient Yes -
Perform site visits, regular teleconference calls as needed Yes -
Escalate potential cases of non-performance, non-compliance, or subaward disputes to ORSP Yes -
Inform ORSP if an invoice cannot be paid because the subrecipient has inadequate deliverables or has made unsatisfactory progress. Yes -
Maintain a record of the subaward agreement and invoices - Yes
Perform subrecipient risk assessment, as applicable - Yes
Incorporate special terms and conditions in subaward based on subrecipient risk assessment - Yes
Assists in the review of subrecipient invoices to ensure invoices are within the parameters of the subaward budget and questioning expenditures if necessary. - Yes
Prepares the appropriate outgoing subaward and any modifications thereafter. - Yes
Requests an annual certification from each subrecipient for compliance with the Single Audit Act. - Yes
Completion of UNF's certifications, representations, and annual audit certification - Yes
Track cumulative totals of subaward invoices Yes Yes
Review that subrecipient expenses are necessary, reasonable, allowable, and allocable Yes Yes
Approve invoices for payment Yes Yes

Subaward Closeouts

Reporting requirements and due dates are established in the subaward, including the requirement for submission of the final invoice, technical report and other reports as may be necessary to fulfill the requirements of the prime award.

 

It is important that ORSP receive final reports from the subrecipient in accordance with the terms and conditions of the subaward so that the ORSP can submit final reports to the prime sponsor by the prime sponsors' deadline date.

Subrecipient Audit Certification

An organization that expends $750,000 or more in federal grant funds awards during its fiscal year is required to provide the appropriate single or program-specific audit in accordance with the provisions outlined in the Federal Uniform Guidance 2CFR 200.501.

 

For the University of North Florida to determine if subrecipients have met audit requirements, subrecipients must complete the Subrecipient Audit Certification Form form and submit applicable audit documents for their most recently completed fiscal year.

 

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