Subrecipient - (as defined in the Uniform Guidance) a “non-federal agency that expends federal funds received from a pass-through entity to carry out objectives of the federal program or award.” A subrecipient, unlike an independent contactor or vendor, is responsible for a portion of the work that is essential to the project. Therefore, a subrecipient is likely to make programmatic decisions, have their own principal investigator, meet specific program objectives through performance measures stipulated in the grant, and comply with applicable federal sponsor requirements. The subrecipient is usually identified at the outset in the original proposal to the funding agency. In the rare instances when this in not the case, sponsor approval of the subrecipient is generally required prior to the subcontract being awarded. Sponsor approval is also required to change the subrecipient named in the original proposal.
Subawards - financial assistance in the form of money made under an award by an award recipient (also called a pass-through entity) to conduct a fundamental section of the scope of work for the sponsored project. Funds are provided to the subrecipient by means of a subaward.
Subgrants/Subcontracts - the instruments used to make subawards to subrecipients.
The Research Foundation (RF) standard boilerplate subgrant is primarily used when the original award to the RF is a grant, when the subawardee is another educational institution, and when the nature of the work largely relates to basic research. The RF standard subcontract boilerplate is the instrument that is used primarily when the original award from the sponsoring agency is a contract. This usually occurs when the substantive portion of the program work is to be conducted by an organization other than another educational institution, and when the scope of work to be performed involves the completion of deliverables in the form of reports or products.
Suballocation - When the subrecipient is another SUNY campus, the award is made to the location by setting up a suballocation within the RF Business system.
By definition the subrecipient will be conducting a substantive portion of the proposed project, the subrecipient is likely to be the key to the proposal and will therefore be identified in the application. A detailed budget breakdown for the proposed subaward, including any cost share requirements, will be included as part of the application total budget. This will include any Facilities and Administrative (F&A) costs to be passed down to the subrecipient, which will necessitate the verification of any applicable fringe benefit and F&A rates. The proposal should also include a well-defined scope of work with clearly defined performance and/or outcome measures, and plainly delineate deliverables and deadlines. The proposed subrecipient’s institutional official must approve the scope of work and budget.
All subawards are drawn under an agreement between the Research Foundation of the State University of New York and the subrecipient. In addition, the Pre-Award and Contract Services Unit is responsible to insure that the correct determination has been made in classifying the individual or firm as a subrecipient, rather than an independent contractor or vendor, or that the services to be provided are not more appropriately classified as that of an employee. The agreement with the subawardee must be reviewed to insure that an “arms length” agreement exists and that the contract is not motivated by potential gain, or even has the appearance of an apparent conflict of interest on the part of the principal investigator (PI). The Pre-Award and Contract Services Unit is also responsible for the completion, negotiation, and execution of the subcontract or subgrant, and for insuring that all of the necessary flow down provisions are incorporated into the agreement. The Grants Management and Purchasing Services Units work with the Pre-Award and Contract Services Unit to insure compliance with sponsor regulations and that documentation of sponsor approval, where appropriate, has been provided. They determine that funds for the subaward have been budgeted in the grant and are available.
The Sponsored Program Operations Sub Award process is outlined on the Subrecipient Process Flow. When a subgrant or subcontract is required, the Principal Investigator should supply the Pre-Award & Contract Services Unit with a completed Subrecipient Procurement Form. The following items must be included in the attachments to the form:
Once the Pre-Award and Contract Services Unit has prepared the contract, Sponsored Programs, Purchasing Services Unit encumbers a purchase order, which commits the funds in the amount of the subaward in the RF Business System. The actual agreement with the subcontractor will be binding only upon the execution of the formal contract between the RF and the subrecipient. The subaward agreement must be signed by a representative of the subrecipient who has the authority to execute such contracts, and by the RF Operations Manager. Principal Investigators should allow at least four to six weeks for the subaward agreement to be fully executed, and should be aware the process could take substantially longer if extensive negotiations are necessary in order for the Research Foundation and the subrecipient to come to terms.
If the subrecipient is another SUNY institution, a formal contract is not necessary. Since the Research Foundation is considered a single entity, sponsor approval is not required.
When a suballocation is required, the project director should supply Sponsored Programs Grants Management Services with a completed suballocation agreement form. This form contains the following information, which is required in order to generate the suballocation:
If cost sharing on the part of the subrecipient is required, list the source of the cost sharing, and identify reporting or documentation requirements.
Documentary evidence that the appropriate institutional official at the location has approved the sub-allocation.
The Sponsored Programs, Grants Management Services and Pre-Award and Contract Services review the suballocation request, and if deemed appropriate, establish a designated project under the prime sponsor award for the campus in the accounting system.
Payments against subcontracts and subgrants are made through the vendor payment process. Advance payments are authorized only if stipulated in the subaward agreement. All other scheduled payments are generated upon receipt of an invoice from the subrecipient, which documents how the funds were expended, and approval of the project director that the services to date were satisfactorily performed. The invoices from the subrecipient are required to contain the following signed certification statement “I certify that the invoice is correct and that it does not duplicate reimbursement of costs or services received from other sources. In addition, I certify that reimbursement is requested only for expenditures on items approved by the terms and conditions of the subcontract with the Foundation.”
Final payment will be processed only after the project director has made the following certification on the Final Payment Authorization form that all of the deliverables under the agreement have been provided. “I certify that reports due by subrecipient have been completed and the technical requirements have been accomplished.”
Changes to the scope, term, or amount of the subgrant or subcontract agreements are authorized only upon execution of a modification to the agreements. Pre-Award and Contract Services is responsible for the negotiation of such modifications.
OMB Uniform Guidance, establishes uniform audits and monitoring requirements for subrecipients. It is incumbent upon the Office of Sponsored Programs and Research Foundation (RF) Central Office Audit Department to insure that the audit requirements of the circular are met. The responsibility for subrecipient monitoring is therefore shared between both the campus and the Research Foundation Central Office, and monitoring guidelines are based on a level of risk associated with a particular subrecipient.
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