SUBAWARD DIVISION
The Subaward Division of the Office of Sponsored Programs and Research Administration (OSPRA) is responsible for processing Subaward Agreements/Amendments that are issued by the University to other organizations. The recipients (subawardees) will perform a portion of the research required under a prime award to the University.
Subaward Agreements received by the University from other entities are processed by the Award Division in OSPRA. Agreements to obtain goods or routine services are purchases, not subawards, and are subject to all relevant University procurement policies. For further information regarding purchase transactions, contact the OBFS Purchasing Division
.
The Subaward Division works with the principal investigator and/or the unit to process Subaward Agreements/Amendments to other organizations performing a distinct scope of work for a research project.
The procedures below are required to process a Subaward Agreement/Amendment in accordance with Section 16.1.5 of the Office of Business and Financial Policies and Procedures Manual ![]()
To initiate the subaward process, the unit business contact must first:
- Assemble such material as the subawardee’s statement of work (SOW), budget, PI identification, and organizational contact information;
- Request initiation or modification of a Subaward Agreement by utilizing the Subaward Request Form or Subaward Amendment Request Form and providing the materials detailed above.
After the receipt of the materials above, OSPRA will:
- Determine if “subawardee” must be selected competitively (vendor) or if sponsor approval must be obtained based on the following:
Identified subawardee. The subaward documents may be initiated without further sponsor approval if:
(1) The University and the subawardee have jointly proposed to the sponsor;
(2) The proposed subawardee was included in the University’s proposal, and/or
(3) The subawardee was approved by the sponsor as a condition of award.
Subawardee not previously identified. The University must ensure that subawardee will perform a portion of the research described in the SOW rather than a procurement of goods or routine services, except when the sponsor requires electronic submission by Grants & Contracts Office - Post Award Administration, e.g., NSF Fastlane. See the Subawardee v. Vendor Table.
- Verify that the prime award has sufficient funding and period of performance available to issue the Subaward Agreement.
- Establish that all necessary approvals have been obtained. If OSPRA determines that sponsor approval is required to issue a Subaward Agreement, the unit is responsible for working with the PI to prepare the request. OSPRA will review and forward the request to the sponsor.
Preparation of a Subaward Agreement by the Subaward Division includes the following steps:
- Review the terms and conditions of the prime award and the corresponding proposal;
- Assign a Subaward Agreement Number;
- Identify the Subawardee’s Principal Investigator(s);
- Document the basis for subawardee selection;
- Determine the legal classification of the subawardee entity to identify the appropriate legal instrument;
- Determine the appropriate payment terms, may be parallel to the payment terms of the prime award;
- Verify subawardee qualifications to:
- Perform any financial analysis necessary to reasonably assure the subawardee has the necessary financial viability to perform the work;
- Determine tax status of the subawardee organization;
- Verify compliance with OMB Circular A-133 audit requirements, if subawardee is a domestic, non-profit organization;
- Review subawardee’s budget and F&A rates; and
- Verify that any F&A rate assessed has been reviewed and approved and/or negotiated with a cognizant audit agency.
- Incorporate the following into the selected legal instrument:
- Applicable terms and conditions of the prime award, including applicable general provisions;
- Any special provisions, including but not limited to (1) Truth in Negotiations (Public Law 87-653) and (2) a Small Business Subcontracting Plan by Subawardee;
- Required Certifications and Representations; and
- Contractor's FEIN
Approval of Subaward Agreement/Amendment:
- PI approval (either via e-mail or signature on agreement)
- Department Head and/or Dean (when deemed necessary)
- Legal Counsel (for subawards involving terms and conditions not previously approved)
Authorization of Subaward Agreement/Amendment:
- University signature by Comptroller and if necessary, Board of Trustees
- Subawardee’s authorized representative
When both parties to the Subaward Agreement/Amendment have signed, the agreement is considered fully-executed and legally binding. Once the fully-executed agreement is processed by OSPRA, it is forwarded to the appropriate accounting section of the Grants and Contracts Office—Post-Award Administration
. An electronic copy of the agreement is sent to the PI and the unit’s business contact.
Subaward Amendment processing:
The unit business contact shall submit a Subaward Amendment Request Form when an amendment to the Subaward Agreement is required. Following are some examples of actions requiring the issuance of an Amendment:
- providing additional funding;
- extending the period of performance;
- incorporating additional terms and conditions;
- changing either the University PI or Subawardee PI; and/or
- incorporating additional/revised SOW and/or budget.
- verify subawardee qualifications for all subaward entities
Monitoring of Subawardees
- The PI (with the unit’s business contact) is responsible for reporting any issues or concerns related to subawardee’s performance or amounts invoiced to the Grants and Contracts Office—Post-Award Administration. For further guidance, see Section 16.1.5 of the OBFS Policy and Procedure Manual
