Subawards: Roles and Responsibilities

Proposing and managing a subaward is a shared responsibility.


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

Principal Investigators (PIs) Primary Responsibilities


  • Establish and maintain communication with subrecipients during proposal preparation and submission.


  • Oversee subrecipient compliance with subaward terms and conditions.
  • Ensure technical performance goals are achieved and aligned with subrecipient's statement of work.
  • Ensure technical deliverables identified in subrecipient statement of work are complete and received in a timely manner, and work with the unit administrator to have receipt recorded in RASS.
  • Review subrecipient invoices as an indication of PI's acknowledgment that subrecipient's technical progress is aligned with invoiced charges.
  • Discuss poor performance or non-performance, or other problems relating to the subrecipient's performance under the subaward with subrecipients and with the Subaward Team as they arise.
  • Approve requests for annual increments of funding for multi-year subawards.

Unit Administrators Primary Responsibilities


  • Assist PIs with the subrecipient proposals to be included in the Cornell proposal to sponsor (statement of work, budget, budget justification, FDP Institutional Letter of Commitment, or Subrecipient Commitment Form signed by the subrecipient's Authorized Organization Official).


  • Initiate subaward request via RASS after the prime award is fully executed and distributed.
  • Request, receive, and review 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, and in accordance with the subaward terms.
    • 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.
  • Request clarification from the subrecipient for invoiced charges if any are unusual, unreasonable, unallowable, or unallocable. If explanations are insufficient, request detailed justifications from subrecipient to verify the appropriateness and reasonableness of the charges in question.
  • Discuss subrecipient poor compliance or non-compliance with subaward terms and conditions with the Subaward Team.
  • Send signed, reviewed, and approved subrecipient invoices to the service center for processing payment in Kuali Financial System (KFS). This should normally be done within 30 days of invoice receipt, and any delay should be documented in an eDoc comment.
  • Assist PIs in carrying out their subrecipient monitoring responsibilities.
  • Maintain documentation of subrecipient monitoring efforts.
  • Submit requests to the Subaward Team via RASS to modify existing subaward (additional time, money, etc.).
  • Assist PIs with requests for annual increments of funding on multi-year subawards.
  • Obtain required reports/deliverables from the subrecipient for PI review and update the date the reports/deliverables were received from the subrecipient in RASS.

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


  • Review subrecipient proposals prior to proposal submission when received by the GCO with sufficient time to complete a full review.
  • Make subrecipient vs contractor determination based on characteristics outlined in 2 CFR 200.331 Subrecipient and contractor determinations).
  • Assess the level of subrecipient risk prior to submitting the proposal to the prime sponsor.


  • Distribute the prime award in RASS including the Subaward Team in the notification to alert the Subaward Team that subawards are included in the project.

Subaward Team (Office of Sponsored Programs) Primary Responsibilities


  • Determine the appropriate type of subaward to issue.
  • Consult with SFS to determine what additional subaward terms and conditions are to be included for elevated-risk subrecipients.
  • Ensure that information required by 2 CFR 200.332 (Requirements for pass-through entities) is included in the subaward agreement when a prime award is from a Federal Prime Sponsor (direct or flow through). Negotiate the terms of the subagreement with the subrecipient.
  • Consult with the prime award GCO, SFS, Risk Management, etc., as required.
  • Identify subrecipients who have been suspended or debarred from receiving federal funding, identified as terrorist entities, or associated with terrorist entities.
  • Review Single Audit reports or other audited financial reports of subrecipients, forwarding those with findings related to, or potentially affecting, Cornell subawards and other audited and/or unaudited financial reports to SFS for their review.
    • Determine the need for and implement recovery and/or adjustment of Cornell’s records, when findings specific to a Cornell subaward exist.
  • Ensure each subrecipient completes a profile questionnaire prior to issuing a subagreement.
  • Gather associated documentation from subrecipients: certificate(s) of insurance, compliance approval certifications, etc.
  • Request and review annual audit reports of subrecipients during the life of the subaward agreement.
  • Receive executed subawards from subrecipients, and reviews the subagreement to ensure that no changes were made to the subagreement terms before obtaining the Cornell signature and providing a fully executed copy of the subagreement to the subrecipient.
  • Distribute fully executed subawards via RASS.
  • Notify PI(s), Co-PI(s), Unit RA(s), and SFS when additional post-award subrecipient monitoring is required for elevated-risk subrecipients.

Sponsored Financial Services (SFS) Primary Responsibilities

  • Review Single Audit reports and/or other audited/unaudited financial reports of proposed subrecipients in collaboration with the Subaward Team and provide recommendations for the risk level of the subrecipient based on the financial position/findings.
  • Establish subaccounts for subawards.
    • Record the budget for subaward obligation in the general ledger.
  • Review the submitted KFS financial eDoc for subaward payment.

Subrecipient Primary Responsibilities


  • Submit FDP Institutional letter of Commitment, or Subrecipient Commitment Form 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.
  • Complete a subrecipient profile questionnaire and other documentation requested to assess subrecipient risk.
  • Review, negotiate, and execute the subaward.


  • Comply with terms and conditions of subaward and prime award (as applicable) terms and conditions.
  • Submit invoices according to timetable and form outlined in the subaward.
  • Submit Technical Progress Reports and other reports and/or deliverables as outlined in the subaward.
  • Request changes to subaward when necessary.