SUBAWARD DETERMINATION

A subaward is issued when a substantive portion of a scope of work under an award will be performed by another entity. When CSU receives an award, a subaward is the instrument used to pass a portion of our award to a subrecipient, whether that subrecipient be another institution of higher education or a non-profit or for-profit organization.

Prior to issuing a subaward, it is important to make an accurate determination of whether the receiving entity is a subrecipient, vendor, or consultant. While there are a number of factors to consider when making a determination, if the receiving entity is performing a substantive portion of the programmatic effort, they will likely be a subrecipient. If the receiving entity is providing goods or services or a particular expertise, then likely they will be a vendor or consultant. (See chart below for further guidance).

It is important to make an accurate determination at the proposal stage for appropriate budgeting and to receive prior approval from the sponsor to issue a subaward.

CSU PRE-AWARD REQUIREMENTS

In order to include a subaward in a grant proposal, CSU needs the following from the subrecipient:

• Approved budget from the subrecipient’s AOR
• Budget justification
• Scope of work
• Completed Proposal Subrecipient Commitment form (Entities in the Federal Demonstration Partnership- FDP- can use the FDP sub-commitment letter.)

Having these items upfront ensures the approved pieces are in place for inclusion in the proposal. These items also aid CSU in determining probably level of risk incurred when entering into a sub-agreement. Risk is dependent upon a number of factors and it is the Institution’s responsibility to perform a risk assessment of our subrecipients.

RISK ASSESSMENT

The Uniform Guidance requires pass-through entities, like CSU, to conduct a risk assessment of their subrecipients (§200.331(b)). A risk assessment is used to determine the likelihood of a subrecipient’s noncompliance with federal regulations. Indicators that an entity might be high-risk include:

• Not registered in SAM.gov
• Little experience accepting Federal funds
• Inadequate financial management systems
• Unaware of cost principles
• No federally negotiated F&A rate
• Lack of experience as an awardee
• International entity or small non- or for-profit organization

If a subrecipient is deemed to be high risk, like a small business or foreign entity, discuss the situation with the subaward administrator, Kris Miller, to determine if the budget and scope of work should be submitted in a task-based format. Issuing a fixed-price agreement based on milestones reduces CSU’s financial risk. Budgeting appropriately at the proposal stage means we don’t have to go back to the sponsor and ask for approval to issue a fixed-price subaward later, which is sure to delay the issuance of the subaward.

ROLES & RESPONSIBILITIES

At CSU, the process of issuing a subaward and subrecipient monitoring is a shared responsibility. The chart below outlines the primary responsibilities of the PI, the OSP, and units such as departments and colleges, in subaward management.

IN CONCLUSION

Acceptance and management of federal funds is a shared responsibility that is ongoing throughout the life of a sponsored agreement. If you have questions regarding subaward administration, consult the OSP website or contact Kris Miller, CSU Subaward Administrator.