The purpose of this document is to assist WHOI Principal Investigators and staff in the preparation of required forms and documents for the issuance of subawards under sponsored research, regardless of the source of funding.
The term Sponsoring Agency refers to the organization that makes an award directly to WHOI. The award document is the agreement processed by the Sponsor and accepted by WHOI specifying the terms under which the program will be conducted. This is often referred to as the Prime Award.
The document that Grant and Contract Services (GCS) generates to formalize a third party relationship with another organization to perform work based upon the Prime Award made to WHOI is called a Subaward. The third party performing the effort under a subaward is called the Subrecipient.
When the procurement requires performance from a sole entity because services or expertise are not available from other sources, the PI is required to provide sole source justification identifying the need for the service and why the selected subrecipient is the only source available for the needed services. Sole source selection is not justified simply by the fact that there has been an ongoing collaboration between the scientists. It must be further justified with reasons for the unavailability of the services or expertise from other sources.
A budget itemized by major budget category, such as salaries and wages, employee benefits, supplies, equipment, travel, consultants, subawards and other direct costs, is submitted by the subrecipient as part of its proposal. Indirect costs should be included and should be calculated using the subrecipient's current rate(s). A copy of the subrecipient's negotiated rate agreement is needed to verify the indirect costs requested and to support those costs in case of an audit and should be attached to the proposal.
The subrecipient's proposal must be signed by a designated official who is authorized to commit the subrecipient's resources to the completion of the project. The subrecipient's proposal is incorporated in WHOI's budget as a direct cost.
Preparing the Subaward
GCS will prepare and issue the subaward when the following are received.
- a fully executed purchase requisition
- Subaward Checklist prepared by Department Administration
- Subaward Budget Information Checklist prepared and signed by the PI
The subaward is normally sent unsigned to the subrecipient for review. The subrecipient may want to negotiate changes or request clarification of the terms and conditions. GCS will negotiate and coordinate those requested changes with department personnel and the PI, where appropriate.
Once this has been accomplished and GCS receives the signed subaward, GCS will execute it on behalf of WHOI and return the fully executed document to the subrecipient and make the proper internal distribution.
Amendments to Subawards
During the term of a subaward, it may be necessary to change or modify one or more of the terms and conditions of the subaward. Some changes such as scope of work or PI may require sponsor approval before an amendment can be issued. Requests for changes should be submitted by the subrecipient's authorized official and have the approval of the WHOI PI before action can be taken by GCS. The Department must send a Change Order to the subaward purchase order to initiate an amendment.
In most cases, the terms and conditions of a subaward will remain unchanged for the duration of the subaward. An exception to this is when the Prime Award to WHOI and the subaward are incrementally funded. Then amendments to the subaward are made when WHOI receives amendments to the Prime Award. Other changes to the subaward, such as no-cost time extensions, rebudgeting, or equipment purchases are accomplished by an amendment to the subaward. If there is a change in the total estimated cost a revised budget must be incorporated with the amendment. The amendment is the vehicle that clearly states the changes and provides for the signature approvals of both parties.
SUBAWARD CLOSEOUT POLICY
It is the Institution's responsibility to perform some type of cost and price analysis on all subawards that are being closed out, therefore a desk audit will be performed by GCS. If during the desk audit, any problems are encountered with the subaward, the matter should be resolved prior to making final payment to the subrecipient. Specifically, the following steps are performed by the Grants Administrator:
- Prepare the Subaward Closeout Checklist to facilitate the collection and summarization of the following information:
- An invoice marked FINAL from the subrecipient.
- A final technical report has been prepared
- Report of Inventions and Subawards (DD Form 882) has been prepared (Prime is a Contract)
- Inventory of Government-owned equipment has been prepared (Prime is a Contract)
- Subrecipient's Release Form has been prepared (Prime is a Contract)
- Subrecipient's Assignment of Refunds, Rebates, Credits, and other amounts has been prepared (Prime is a Contract)
- Subaward Release of Claimes (Prime is a Grant or Cooperative Agreement)
- The desk audit, completed by the Director of GCS, will include the following steps:
- Compare the actual overhead rates charged to the subrecipient's negotiated rates and reconcile any differences.
- Compare the total amount of the subaward with the ceiling price to ensure that it has not been exceeded.
- Review the final invoice for overall reasonableness and accuracy.
- Determine that the PI is satisfied with the results and deliverables.
- If any exceptions or questions arise as a result of performing the above they will be discussed directly with the subrecipient organization. After all issues have been resolved, then the final invoice is processed for payment. The completed checklist and signed Desk Audit with all the attachments is then filed in the subaward file in GCS.
Last updated: January 14, 2014