Department Confirmation of Subaward Agreement Information
When we receive the prime award at SPA, we start a subaward file. The award issued to the subrecipient is dependent on the terms of the prime award and the risk analysis results we compile.
After reviewing the prime award, your GA will contact the University principal investigator (PI) and/or department administrator to confirm or request the following information regarding the subaward:
- Period of performance—may not be outside of the University’s period of performance for the prime award, but may be issued for a shorter period than the prime award term.
- Statement of work
- Budget (including cost share, if applicable) and budget justification
- Payment terms and schedule
- Technical and financial reporting requirements
- A best practice is to require reports to adequately monitor progress and fulfill reporting requirements to the sponsor. For example, for awards with an annual and final progress report requirement, the UMN PI should consider requiring the subrecipient to provide an annual and final progress report covering their portion of the project to the UMN PI. the progress report should be provided in sufficient time to allow the subaward information to be incorporated into UMN’s progress report to the sponsor.
- UMN PIs should remember that requesting increased reporting increases their administrative burden and that of their department as they become responsible for ensuring that all required reports are received, reviewed, and their acceptability documented.
- Verification that subrecipient is compliant with IRB, IACUC, and IBC approvals (if applicable)
- Subrecipient’s contact information
- Other information as needed (Fair & Reasonable Cost Analysis Form II)
- Approval of funds to carryforward between budget periods (if allowed by prime)
Subawards Not in Proposal
If subrecipient was not included in the original proposal, prior approval from the prime sponsor is likely needed prior to issuing subaward. Consider using the Fair & Reasonable Cost Analysis Form 1 as a tool to gather all required information for this request.
The request to the sponsor should include the subaward statement of work, budget, and budget justification, and how the UMN will rebudget the overall grant budget and scope of work to accommodate the subaward not included in the original proposal.
Risk Analysis & Compliance Review
Uniform Guidance requires a risk analysis be completed by the UMN to evaluate the likelihood that a subrecipient will fail to comply with the requirements of the subaward. We will do this during the issuance process and monitor it during the life of the subaward. The criteria used in evaluating risk can include the subrecipient's audit experience; the prior oversight and monitoring the subrecipient has received; the size, nature, and complexity of the proposed research project; and the fiscal maturity of the subrecipient.
If the subrecipient is not subject to the Uniform Guidance Single Audit requirement, SPA may contact the subrecipient to obtain a copy of their audit or may be asked to complete a Financial Questionnaire to complete the risk analysis. SPA will also verify that FCOI documentation is on file. If the subrecipient is using the UMN’s FCOI policy, they will need to complete online FCOI training and will need to provide a disclosure form annually.
SPA will complete reporting in accordance with the Federal Funding Accountability and Transparency Act (FFATA) which requires that the UMN reports federal subawards it issues over $25,000.
SPA will also conduct a suspension and debarment check and a review of the F&A rate application.
Agreement Negotiation & Execution
The subrecipient may want to negotiate changes or request clarification of the terms and conditions of the subaward. SPA will negotiate these changes with the subrecipient, and seek approval from PI and/or department personnel as needed.
Once the subaward is signed by the subrecipient and SPA, a copy of the fully executed subaward will be sent to the PI and department administrator via email. The subaward funding will be encumbered in EFS after the subaward is fully signed.