A “federal subaward” occurs when DePaul awards a portion of a federal grant to another organization to carry about part of the grant project in cooperation with DePaul. The Uniform Guidance establishes requirements involving the issuing and monitoring and such subawards that are more extensive and detailed than previous federal guidance on this topic. Following are guidelines, procedures, and document templates that facilitate compliance with these requirements.
Making Subrecipient vs. Contractor Determinations
Before issuing a federal subaward, DePaul must confirm that the recipient organization will be cooperating will us to fulfill the project goals, as opposed to serving as a vendor of goods or services. The criteria included in the Uniform Guidance for making this determination are summarized in the attached table. See the table .
Procedures for Issuing and Monitoring Federal Subawards
It is the responsibility of the PI to maintain oversight of the sponsored project. Unbiased research activities and cultivating an environment of research integrity are paramount. While the PI may delegate responsibility for some project activities, the PI is ultimately responsible for compliance with all applicable regulations and policies. ORS and Restricted Accounting share responsibilities with the PI, to maintain overall compliance for sponsored projects.
PI Responsibilities
- Confirm that the subaward is included in the budget awarded by the federal agency/other sponsor. If a new subaward needs to be added to a funded project, sponsor approval may be required.
- Make sure that the proposed budget has been fully funded or the subaward amount has been adjusted, as needed.
- When the subaward is ready to be issued, the PI should notify ORS.
Once the subaward agreement is issued, the PI should be monitoring the activities and performance of the subrecipient throughout the life of the subaward by:
- Receiving data and progress reports
- Receiving deliverables defined in subaward agreement
- Participation in project conference calls
- Subrecipient will submit invoices to the Unit in accordance with the subaward agreement, but generally not more frequently than monthly
Office of Research Services and Restricted Accounting Responsibilities
- Conduct a subrecipient risk assessment: A subrecipient risk assessment is conducted, and subaward terms and conditions are written to address the corresponding level of risk. The prime sponsor holds DePaul University responsible for the performance of work by subrecipients.
- Complete subrecipient monitoring: Subrecipient monitoring enables DePaul University to review scientific progress, expense allocation, and confirm that the subrecipient is performing according to the Principal Investigator’s programmatic needs. For outgoing subawards (from DePaul), most of the primary award terms and conditions will flow through to the subrecipient, particularly the regulatory requirements and obligations. The subaward agreement will also incorporate the subrecipient’s proposed scope of work and budget. Adjustments might be necessary if the prime award is reduced.
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