1. Subaward Life Cycle
10/24/17

2. Agenda Important Definition Life of a sub-award Resources Pre-award
Post Award
Closeout
Resources
Subaward process:

3. Definitions Subaward Contractor (Vendor)
Provides a significant portion of the programmatic effort
Retains rights to IP
Is responsible to adhere to all applicable federal compliance
Is usually another higher ed. Institution, hospital or other non profit organization
Contractor (Vendor)
Provides goods or services to many different businesses
Normally operates in a competitive environment
Is not subject to compliance of the federal program
Can be a company or an individual

4. Proposal Preparation Stage
Pre-Award
Award
Post-Award
Closeout
Proposal Preparation Stage

5. Department/PI: Pre-Award Sub
Notify OSP of upcoming proposal and provide RFP
PI requests proposal package from proposed subrecipient, to include:
Required: Statement of Work, Detailed Budget, Budget Justification, Subrecipient Commitment Form, Other documents as required by Sponsor
Recommended: Subrecipient F&A Rate Agreement and Subrecipient Fringe Benefits Rate Agreement
To be conducted by OSP: Audit/Financial Status verification and Subrecipient Risk Analysis
If applicable: Human subjects and/or Animal subjects approval docs
Subaward checklist available online:
Sub commitment form:
The initial award stage, for the purposes of this policy is a stage that includes both proposal development through award set-up. The goal of subrecipient monitoring efforts at this stage is to ensure that the subrecipient is capable of compliantly spending the funds and meeting the project goals. Subrecipient completes the Subrecipient Commitment Form which provides an initial assessment of their ability to manage funds.

6. Department/PI: Proposal with Subs
Proposal with a subaward include the following:
Subrecipient proposal into BC full proposal
Subrecipient’s budget total as a single direct cost line item in BC budget
IDC is applied to the first $25K of each sub
Other forms (e.g, budget, biosketches, other support) as required by BC’s sponsor
Forward completed BC proposal to OSP Rep for review
Subaward checklist available online:

7. Office of Sponsored Programs: Pre-award
Review RFP and agency/foundation requirements
Complete Sub Review to include
Letter of Commitment
Statement of Work
Budget and Budget Justification
F&A Rate Agreement
Confirm they can adhere to prime guidelines and has a financial conflict of interest policy in place

8. Pre-Award
Award
Post-Award
Closeout
Award Stage

9. Department/PI: Proposal Awarded
Once, OSP notifies department of award:
Department submits the Subaward Initiation Request Form and the supporting documentation to OSP
Upon receipt of signed agreement, Department works with Purchasing to initiate the issuance of a Purchase Order
Subaward initiation form:

10. OSP: Award Stage OSP notifies department of award
Dept. sub initiation form is received
Obtain completed subrecipient questionnaire
Obtain completed commitment form
Determine financial adequacy of the sub recipient
Obtain evidence of most recent F&A rate agreement
Verify the subrecepient is not on debarred list
Complete risk assessment
Red flags: History of noncompliance, new to the efforts, etc.)

11. Potential Indicators of High-Risk
A qualified audit report, or failure to have a current audit report
Inadequate response to a financial questionnaire
History of non-compliance
History of non-performance or failure to use funds for their authorized purposes
New subrecipient (or new to this type of project)

12. to High Risk Sub-recipients
Potential Resolution
to High Risk Sub-recipients
Discuss need for special monitoring with PI/department
Ask for extra contact between PI and Sub’s PI
Ask for more frequent technical/financial reporting
Add more detailed or frequent invoicing requirements
Add requirement for expenditure backup materials
Tie receipt of technical progress reports to payments
Require on-site monitoring (technical and financial)
Add more stringent termination language for failure to comply with requirements

13. Preparing the Sub-Award

14. OSP: Preparing Sub-Award
Statement of Work
Key Personnel
Period of Performance
Dollar Amount
Payment Terms
Prior Approvals
Cost Sharing
Reporting Requirements
Intellectual Property
Flow down requirements

15. Monitoring an Active Sub-award

16. Pre-Award
Award
Post-Award
Closeout
Post-Award

17. OSP: Subaward Monitoring
Communicate problems with OSP on reporting/deliverables
Annual review of active subs Single audit handled by OSP Compliance
Review Audit clearinghouse
Follow up with sub with any issues
Maintain the subrecipient risk assessment process

18. Department/PI: Subaward Monitoring
PI monitors subrecipient technical progress
Communicate regularly with subrecipient PI to monitor progress on the project
Monitor receipt of technical reports for timeliness and content
Communicate with OSP if changes need to be made to work statement, reporting requirements, budgeting.
PI/Department monitors subrecipient’s adherence to terms

19. Department/PI: Subaward Monitoring
PI/Department reviews invoices
Are they arriving on schedule?
If not, PI/Department contacts subrecipient for invoices
Do they contain the right level of detail to allow adequate review, and are they in accordance with the agreement?
Ensures all costs are allowable, allocable and reasonable
Ensures all costs were incurred within the period of performance of the subaward
Confirms that expenses are aligned with technical progress
Cost sharing is appropriately reflected, if required
If acceptable, PI signs and dates invoice
PI/Department sends invoice to Procurement Services for processing
PI/Department reviews Transaction Detail Report (TDR) to verify that approved invoices appear on the project
From last month’s BRIEF:
• Invoice lists detailed accounts / costs
• Invoiced costs are in the approved agreement budget – NO DEVIATIONS
• Recalculate invoice including fringe and F&A costs
• Total expenses for sub < total amount obligated to date
• Ensure costs are incurred during the correct budget period
• Ensure the following are on the sub’s invoice: BC project number; costs are in US dollars; dates of costs/services
• Ensure subs submit invoices timely especially near closeout
• If questions/concerns, discuss with sub (also OSP as needed)
• PI/Dept stamp - PI signature with date

20. Department/PI: Subaward Monitoring
If questions/concerns, discuss with sub and OSP as needed
Speak with OSP Post-Award contact if unsure of whether charges are allowable
Return to subrecipient for more detail or backup documentation
Encourage subs to ask about allowability before incurring costs

21. Subaward Monitoring: Case Study
Please take 10 minutes to read the case and review the questions with your table

22. Department/PI: Subaward Modification
PI/Department submits a completed Subaward Modification Request Form to OSP
Provide supporting documentation (updated budget and SOW if needed) for the amendment
OSP will issue the amendment and will provide copies of the fully executed document to the PI/Department
PI/Department will submit Purchase Order Change Request reflecting the increase / decrease in the dollar amount in the amendment, and will change the due date on the PO if the Period of Performance has changed
Subaward Modification Request Form:

23. Pre-Award
Award
Post-Award
Closeout
Closeout

24. OSP: Closeout Closeout form is received from Sub
Work with Dept. to deob if needed
Review sponsor closeout requirement completed
1. Patent/invention report
2. Property report
3. Signed Release and assignment

25. Department/PI: Closeout
PI/Department plan for a timely closeout
Check status with subrecipient 90 days before end
Follow up on any late or missing reports or deliverables
Obtain final invoice (marked FINAL) from subrecipient
Send copy of final invoice to OSP rep

26. Resources Links: http://www.bc.edu/research/osp.html

27. Questions?
Contact OSP