At the proposal stage, the Principal Investigator should work with their unit administrator and/or OSP to identify subrecipient(s) based on scientific considerations, technical resources, and the ability to perform and complete the proposed statement of work. Use the ‘Subrecipient vs. Contractor Determination Checklist’ form to assist in making a determination.

For entities identified as subrecipient, a clearly defined Scope of Work, a detailed budget, and a budget justification for the subrecipient’s portion of the project should be included in the submission to the sponsor. Additionally, a form of commitment should be included in the KR PD record.

• Use the ‘FDP Subrecipient Letter Template’ if the entity is listed in the FDP Expanded Clearinghouse. (Note: Entities do not have to be FDP members to be listed in the Clearinghouse).
• Use the ‘Proposal Subrecipient Commitment’ form if the entity is not listed in the Clearinghouse.

Per federal guidance, OSP must perform a comprehensive risk assessment of every subrecipient. The OSP Subaward Team performs an annual review of a subrecipient’s single audit or financial records to evaluate risk.
If the subrecipient is deemed by OSP to be high risk, additional oversight may be required throughout the life of the subaward which may include issuing a fixed-price budget, special invoicing instructions, or corrective action plan for high-risk areas. Examples of high-risk subrecipients may include:

• Entities outside the U.S. or European Union
• Small businesses or start-up companies
• Subrecipients with audit findings

If you suspect a subrecipient may be high-risk, work with your OSP RA or OSP Subaward Team to ensure appropriate measures (e.g. task-based, fixed price agreement) and/or monitoring is in place.

Set Up

• A ‘PI Request to Initiate Subaward’ is received by an OSP S/RA.
• The OSP S/RA submits all required subaward documents to the OSP Subaward Team with the request to issue.
• The OSP Subaward Team drafts the subaward and negotiates it with the subrecipient.
• Once fully executed, the OSP Subaward Team notifies the Fiscal Officer so that a requisition request can be created.
• The requisition routes to the OSP Subaward Invoicing Administrator and a Purchase Order (PO) is created.

Administration

It is the responsibility of the Principal Investigator to monitor subrecipients to ensure the performance objectives outlined in the scope of work are being achieved and that funds are being spent in accordance with the award terms and conditions. 

Any modifications to existing subaward agreements should begin with the OSP S/RA. If funding is added, the OSP Subaward Invoicing Administrator will update the PO.

PIs are responsible for reviewing subrecipient invoices to monitor subrecipient activities and expenditures. If the PI has concerns or is unsatisfied with the subrecipient’s performance or deliverables, including technical reports, the PI should reach out to the subrecipient before approving an invoice. Get OSP involved early if there is no improvement in the subrecipient’s performance.

Invoices must be processed and responded to or paid within 30 days of receipt. Final invoices should be marked as ‘Final’ and the billing period on the final invoice should cover the life of the award.

Approved and rejected invoices should be emailed to:
[email protected].

Confirmation of the receipt of the final invoice from the subrecipient is crucial for closing out the subaward. The final invoice should be marked as ‘Final’ and the billing period on the final invoice should cover the life of the award.

Once the final invoice is paid, the PO is closed by the Subaward Invoicing Administrator and any remaining funding is disencumbered. Any requests to close a PO associated with a subaward (75xx object codes) should be sent to [email protected].

In addition to final invoicing, PIs should request any final technical reports, invention statements, or information needed to administratively close the award.

Investigators are encouraged to reach out to the Subrecipient Manager with any concerns relating to a subrecipient’s performance and/or expenditures.