Subawards: Roles and Responsibilities

Proposing and managing a subaward is a shared responsibility.

Roles

  • Principal Investigator
  • Unit Administrator
  • Grant and Contract Officer (OSP)
  • Subaward Services Team (OSP)
  • Sponsored Financial Services (SFS)
  • Subrecipient

Principal Investigators (PIs) Primary Responsibilities

Proposal

  • Establishing and maintaining communication with subrecipients during proposal preparation and submission, and after subaward is issued

Award

  • Oversight of subrecipient's compliance with subaward terms and conditions
  • Ensuring technical performance goals are achieved and aligned with subrecipient's statement of work
  • Ensuring technical deliverables identified in subrecipient statement of work are complete and received in a timely manner
  • Reviewing subrecipient invoices as an indication of PI's acknowledgement that subrecipient's technical progress is aligned with invoiced charges
  • Discussing poor performance or non-performance, or other problems relating to the subrecipient's performance under the subaward with subrecipients and with GCOs as they arise
  • Approving requests for annual increments of funding for multi-year subawards

Unit Administrators Primary Responsibilities

Proposal

  • Assisting PIs with the subrecipient proposals to be included in the Cornell proposal to sponsor (statement of work, budget, letter of commitment signed by the subrecipient Authorized Organization Official)

Award

  • Submitting to OSP via RASS a request to issue a subaward agreement after the prime award is fully executed
  • Receiving and reviewing subrecipient invoices to ensure:
    • Compliance with subaward terms and conditions
    • Costs are aligned with subrecipient's proposal (budget and statement of work
    • Costs are allowable, allocable and reasonable
    • F&A is calculated correctly
    • All costs were incurred within the period of performance of the subaward
    • Subrecipient expenses are aligned with subrecipient technical progress
    • Cost-sharing commitments (if applicable) are met by the subrecipient
    • The correct subaward number is identified on the invoice
    • The invoice has a certification statement that the costs for reimbursement and any corresponding cost-sharing are the actual costs as recorded by subrecipient and expended for the work performed in accordance with the terms of the subaward
    • The invoice is signed by an Authorized Institutional Official
    • The invoice is correctly marked "Final" if it is the final invoice
    • The invoice is reviewed by the Cornell PI according to the procedure outlined
  • Requesting subrecipient clarify invoiced charges if any unusual, unreasonable, unallowable, unallocable charges are invoiced. If explanations are insufficient, detailed justifications should be requested from subrecipient to verify appropriateness and reasonableness of charges in question.
  • Discussing subrecipient poor compliance or non-compliance with subaward terms and conditions with GCO
  • Sending signed, reviewed, and approved subrecipient invoices to SFS
  • Assisting PIs in carrying out their subrecipient monitoring responsibilities
  • Maintaining documentation of subrecipient monitoring efforts
  • Submitting to OSP via RASS requests to modify existing subaward (additional time, money, etc.)
  • Assisting PIs with requests for annual increments of funding on multi-year subawards

Grant and Contract Officers (Office of Sponsored Programs) Primary Responsibilities

Proposal

  • Reviewing subrecipient proposals prior to proposal submission
  • Assessing the level of subrecipient risk prior to issuing a subaward

Award

  • Determining the appropriate type of subaward to issue
  • Working with SFS to identify additional terms and conditions for the subaward for medium and high risk subrecipients
  • Negotiating terms and conditions and issuing resulting subaward to subrecipients
  • Notifying PIs and units when additional post-award subrecipient monitoring by PI and unit is required for medium and high risk subrecipients

Subaward Services Team (Office of Sponsored Programs) Primary Responsibilities

Proposal

  • Identifying subrecipients who have been suspended or debarred from receiving federal funding, identified as terrorist entities, or associated with terrorist entities
  • Reviewing Single Audit reports or other audited financial reports of subrecipients in collaboration with SFS
  • Ensuring each subrecipient completes a profile questionnaire
  • Gathering associated documentation from subrecipients: certificate of insurance, compliance approvals certifications, etc.
  • Requesting and reviewing annual audit reports of subrecipients during the life of the subaward agreement
  • Receiving fully executed subawards from subrecipients
  • Distributing fully executed subawards to PIs and units

Sponsored Financial Services (SFS) Primary Responsibilities

  • Reviewing Single Audit reports or other audited financial reports of proposed subrecipients in collaboration with Subaward Services Team and providing recommendations for medium and high risk subrecipients
  • Reviewing subrecipient risk assessments for medium and high risk subrecipients and recommending post-award subrecipient monitoring actions to Grant and Contract Officers
  • Establishing subaccounts for subawards
  • Reviewing and processing invoices submitted for payment

Subrecipient Primary Responsibilities

Proposal

  • Submitting a letter of commitment signed by an authorized institutional official, a statement of work, budget, negotiated rate agreement and employee benefit rate agreement if applicable, letters of institutional approval if human participants or vertebrate animals are involved in the proposed work
  • Completing a subrecipient profile questionnaire and other documentation requested to assess subrecipient risk
  • Reviewing, negotiating and executing the subaward

Award

  • Complying with terms and conditions of subaward
  • Submitting invoices according to timetable and form defined in subaward
  • Submitting Technical Progress Reports and other deliverables as defined in the subaward
  • Requesting changes to subaward