Purpose

This GIM sets out the policy and outlines procedures for the administration of subawards issued by the University under a prime agreement (contract, grant or cooperative agreement) awarded to the University.

When the University issues a subaward, it maintains responsibility to the prime sponsor for managing the funds and ensuring performance meets the expectations under the prime agreement. This policy and associated procedures are developed with the intent to manage risk of subaward issuance, set out responsibilities related to administering and monitoring subawards, and ensure compliance with federal, state and local laws that affect the performance under, and the administration of, subawards.

Background

A subaward is a special type of agreement that differs in several respects from those for the more standardized procurement of goods and services from commercial vendors. The distinction between a subrecipient and a vendor is based on the federal guidance found within OMB Circular A-133, Attachment A.

The issuance of a contract to procure goods and services is managed by University Procurement Services whereas a subaward is issued by the Office of Sponsored Programs (OSP).

The prime sponsor's award to the University usually includes specific authorization for the subaward. Occasionally, the need for a subrecipient's collaboration develops after an award has been made to the University. Under those circumstances, most sponsor policies require that the University obtain sponsor approval of the subaward before it is entered into by both parties.

Persons / Offices Affected

UW Principal Investigators and Departments, Subrecipients, Office of Sponsored Programs, Payables Administration, and Grant and Contract Accounting.

University Policy

To ensure compliance with the prime sponsor funding, regardless of the grant or contract fund source, the Office of Sponsored Programs (OSP) prepares and administers subawards in accordance with Federal policy found in OMB Circulars A-110, A-21, and A-133 and sponsor policies found in the prime award to the University.

Subawards cannot be issued until the University has received and processed the prime award (e.g. the prime funding is in a "processed" status and has received a budget number) and the related purchase requisition, subrecipient supporting documents, and other information requested from the subrecipient, are provided to OSP.

Subawards may only be issued on behalf of the University by the institutional officials with delegated signature authority within the Office of Sponsored Programs.

Procedures and Guidance

• Identification of Need and Selection of subrecipients
• Preparing a proposal that includes proposed subrecipients
• Small Business Subcontracting Plans
• Subaward issuance
• Title to equipment under a subaward
• Audit compliance by subawardees
• Subaward monitoring and payment
• Termination and closeout of subaward

Responsibilities

Office of Sponsored Programs (OSP)

• Final review of the prime proposal including making sure an authorized official has signed the subaward proposal, especially to ensure the correct Facilities & Administrative (F&A) cost rate has been used in the request for funding.
• Issuance of the subaward, including negotiation of terms.
• Execution and distribution of copies of the subaward, and encumbrance ordering of funds in the payables system.
• Coordination of the proper close out of the subcontract, including final technical report, final invoice and close out certification (the latter where necessary).

Principal Investigator

• PI is responsible for initial proposal documentation including:
  • Presence of all subcontractor proposal materials, including budget, budget justification and letter of commitment.
  • Reasonableness of budget in light of the statement of work.
  • Small Business Subcontracting Plan where necessary.
• Justification for selection of subrecipient within departmental file.
• Ensuring timely submission of subawardee invoices.
• Review and approval of subaward invoices and submission to Accounts Payable office.
• Monitoring of the subaward activities, progress, compliance and expenditures.
• Notification to OSP subaward team (ospsubs@uw.edu) in the event that a modification to the subcontract is necessary.
• Collection of subrecipient closeout materials, including final invention statement, final technical report, final invoice and Close Out Certification Form (if applicable).

Definitions

Originating sponsor:

The sponsor to the University of Washington.

Prime institution:

Institution which received the sponsored agreement directly from the sponsor.

Purchase requisition:

An order initiated by a campus department to purchase goods and services. The requisition provides details to describe a needed purchase.

Subaward:

Binding legal contract between UW and another institution or entity regarding completion of part of a sponsored program.

Subawardee, subrecipient:

Institution receiving a subaward or subcontract from prime institution.

Other Related Resources

Contacts

Content Creator

Office of Sponsored Programs

Office of Sponsored Programs
4333 Brooklyn Ave NE | Box 359472
Seattle, WA 98195-9472 | (206) 543-4043 | Fax 685-1732 | Contact Us
Modified: August 23, 2012