A subaward (subcontract) is an agreement to use sponsored project funding to engage a collaborating institution or agency to perform a substantive portion of a grant or contract’s programmatic effort outside of the University of Houston. The Office of Contracts and Grants (OCG) is responsible for processing and setting up all subawards.
Below is a chart that outlines the steps, the responsible office and person, and the estimated time to complete the process.
|Steps||Responsible Office or Person||Timing|
At the proposal stage, a sub-recipient is recommended and the sub-award is budgetedIf the sub-recipient is not included and approved at the proposal stage, prior approval from the sponsor is required
|Principal Investigator||At the proposal stage or prior to award setup|
|Complete and submit the “Request to issue form” with sub-recipient budget and scope of work (SOW)||
Department Business Administrator (DBA)Principal Investigator (PI)
|On issue date of the prime award or when the PI learns that the award is forthcoming|
Prepare setup documentation, including obtaining the necessary demographic information from the sub-recipient for vendor setup, risk assessment and the terms and condition of the agreement
|Office of Contracts and Grants||Within 2 days after receiving the completed Request to Issue form|
|Create draft agreement for review by the PI. If acceptable, issue the agreement to the sub-recipient Sponsored Project Office for review, negotiations if necessary, and signature||Office of Contracts and Grants||Within 1 day of receiving the completed data sheet from the sub-recipient|
|If the research includes human or animal subjects, the sub-recipient will need to obtain IRB/IACUC approvals||Sub-Recipient||Timeline based on sub-recipient procedures, can delay execution of the agreement|
|If the sponsor requires Financial Conflict Of Interest (FCOI) disclosure, and the sub-recipient is not compliant, they must use the university’s policy||
Sub-RecipientDivision of Research (DOR) Research Integrity Office (RIO)
|Timeline based on sub-recipient procedures, can delay execution of the agreement|
|Execute the agreement when it is returned and encumber the sub-recipient’s budget on the prime award for invoice payment||Office of Contracts and Grants||Within 3 working days of receipt of data sheet from sub-recipient|
The level of monitoring will depend on the result of the risk assessment. The PI is responsible for the receipt and review of technical reports and other deliverables submitted by the sub-recipient. OCG is responsible for reviewing the sub invoices and expenses to ensure compliance with the prime award terms and conditions. It is important that the PI ensure and certify that the required results and deliverables have been completed and the sub is making satisfactory progress before payments are made to the sub. This is the only opportunity to hold the sub-recipient accountable for the work they were subcontracted to do.
Reporting Under FFATA
To reduce wasteful spending in the government, the Federal Funding Accountability and Transparency Act (FFATA) was introduced in September 26, 2006. The legislation requires that information on federal awards be made publicly available through a single, searchable website. As such, all sub-awards from federal funds over $25,000 must be reported within the specific time.
Encumbering the Sub-recipient and IDC Charged
The full amount of the sub-recipient budget is encumbered on the primary grant cost center to ensure that funds are set aside to reimburse the sub. The award’s IDC rate is applied to the first $25,000 paid to each sub. The remaining payment in excess of the first $25,000.00 is exempt from IDC.
Any changes to a sub-recipient agreement must be in the form of a written amendment signed by both parties. The PI must send OCG a request to change any of the provisions in the original agreement. For multi-year projects, OCG will initiate the amendment for the next budget period when all other terms and conditions remain the same.
Working with Foreign Sub-recipients
Foreign sub-recipients may not include all of the information required on the award setup documentation nor may they have the same practices and processes for managing awards. It is important to begin working early with foreign sub-recipient to address these issues. A DUNS number and registration in SAM are required for all entities participating in projects funded by federal agencies.
Early Termination of Agreement
Should the PI determine that it is necessary to terminate a sub-recipient agreement, he/she should contact OCG. OCG will forward a stop work order to the sub-recipient in accordance with the agreement’s termination clause, and will follow with a formal contract modification that includes notifying the prime sponsor, and subaward close out.
End of the Agreement
At the end of the indicated expiration date, the sub-recipient must send the final invoices by the date specified in the agreement. An OCG Administrator will verify with the PI that all final reports are received before completing the release of claim form. All final reports required from the sub-recipient are named in the agreement and may include patent and invention reports, property reports, HUB vendor reports, or other closeout reports as required. The sub-recipient’s final reports are reviewed and then incorporated or combined with the university’s final report for submission to the sponsor.