Subaward Monitoring and Management
Subaward Management Team
What We Do, Commitment Statement
The Subaward Management Team was formed in July 2015 to provide support to faculty and administrators for the negotiation, execution and monitoring of all outgoing subawards (both federal and non-federal) issued under grants and contracts managed by the Office of Sponsored Projects (OSP).
Under the direction of the Associate Director of Subaward Management, the team’s responsibility is to provide outstanding support to faculty and the business offices that support them, as well as protect Yale from financial and compliance risk associated with subawards.
The Subaward Management Team is staffed with Subaward Managers who draft and negotiate outgoing subaward agreements and amendments for the University under both federal and non-federal sponsored awards that are managed by OSP. Each agreement and amendment is carefully customized based on the prime award. The team engages with departments and Principal Investigators (PIs) to confirm budgets and verify compliance with invoicing and reporting requirements. Subaward Managers also assist with the negotiation of terms and conditions and work with domestic and foreign subrecipients to facilitate agreements that are compliant with Yale and sponsor policies. Agreements and amendments are closely monitored through the stages of execution and on an annual basis. Additionally, Subaward Managers may set up subaward grant lines and are responsible for setting up supplier contracts in the Workday system. On most subawards, they are the Administrative Contacts who receive a Subrecipient’s questions and prior approval requests throughout the life of the agreement.
The Subaward Management Team’s Senior Financial Analyst coordinates monthly FFATA (Federal Funding Accountability and Transparency Act) reporting to the federal government and conducts quarterly desk reviews of randomly selected subawards and their corresponding financial records to ensure accuracy. On an annual basis, the Senior Financial Analyst also assists with monitoring active subrecipients by collecting and reviewing audit materials for assessment of financial status and internal controls.
Our team is committed to Yale’s collaborative efforts and will provide the research community with outstanding levels of customer service, timely responses and value-added results. Yale’s mission and the needs of the faculty are at the forefront of all we do.
What is an Outgoing Subaward?
An outgoing subaward is an agreement with a third-party organization performing a significant portion of a Yale research project or program. The terms of the relationship (subgrant/subcontract) are determined by the prime award received by the University. A subrecipient works collaboratively with the prime award recipient to carry out a significant portion of the prime award’s scope of work.
Just because another entity is involved in a sponsored project does not mean that a subrecipient relationship exists. It is sometimes difficult to tell the difference between a subrecipient and a vendor and may be easy to confuse the two. Misclassifying the type of relationship can lead to problems managing a sponsored project so it is important to ascertain if the work to be carried out meets the definition of a “subaward” at the proposal stage.
Determination of Subrecipient vs. Vendor
It is important to differentiate between subrecipients and vendors before entering into an agreement with a third-party organization performing a portion of Yale’s research project. This classification will determine the type of legal agreement as well as the type of monitoring required for the relationship. Misclassification may result in delays in subaward processing, as well as inclusion of incorrect facilities and administrative (F&A) costs, leading to significant budgetary errors. Yale follows the requirements in the OMB Uniform Guidance (2 CFR 200), Section 200.330 to determine subrecipient or contractor status.
The table below describes the characteristics typical of either a subrecipient relationship or a vendor relationship with Yale:
|Subrecipient Relationship||Vendor Relationship|
|The principal goal of engaging the entity is to carry out a public purpose authorized by Yale’s prime award||The principal purpose is to acquire goods or services for the direct benefit of an award|
|The performance of the entity is measured against the objectives of the prime award||The entity provides the goods and services within normal business operations|
|The entity has programmatic decision-making responsibility||The entity provides similar goods or services to many different purchasers|
|The entity receives prime award funds from Yale through a subaward to carry out its own program||The entity normally operates in a competitive environment|
|The entity exercises considerable discretionary judgment||The entity provides goods or services that are ancillary to the operation of the prime award program|
|The entity may be required to provide matching funds or cost sharing dollars||The entity provides services of a repetitive nature or goods of a commonly available kind|
|The entity has its performance measured in relation to whether objectives of sponsored award were met||The entity is generally not subject to compliance requirements of the federal program as a result of the agreement, though similar requirements may apply based on the scope of work (e.g., IRB approval, COI).|
|The entity is responsible for adherence to applicable federal program requirements specified in the federal award if under a federal prime award or the requirements of the non-federal sponsor, as appropriate|
OMB Uniform Guidance allows grantees to use judgment in determining whether a relationship is that of subrecipient or contractor. Not all characteristics listed above will be present. Conversely, the presence of many of the characteristics is not necessarily determinative. Thus, the substance of the relationship is more important than the form of the agreement.
OSP has developed a Subrecipient vs. Vendor Checklist tool to assist in making the correct determination.
Submitting a Proposal with a Subaward
Yale PIs should alert their DBO (department business office) as early as possible of their intent to include a subrecipient in a proposal in order to allow time for the collection of required information and certifications from the subrecipient. If the PI hasn’t identified a specific subrecipient at the time of proposal, the subrecipient will be identified as “TBD (to be determined)” in the budget and proposal.
Subaward Documentation Required During Proposal Preparation
- Subrecipient Statement of Collaborative Intent
- Yale is a participant in the Federal Demonstration Partnership (FDP) Expanded Clearinghouse.
- If the subrecipient organization is an FDP participating institution, a Letter of Intent should be completed by the subrecipient.
- If the subrecipient is a non-participating institution, the Subrecipient Information and Compliance form must be completed by the subrecipient.
- Scope of Work
- Budget and Justification
- Federally negotiated F&A Rate Agreement, if applicable
- Any other documents required by sponsor (e.g., certifications, assurances, etc.)
Proposals may not be submitted to a Public Health Service (“PHS”) agency, a PHS-like sponsor, or the National Science Foundation (“NSF”) without certification from the subrecipient that it has a compliant policy and has made all required disclosures.
For a list of PHS agencies and PHS-like sponsors, visit the Frequently Asked Questions for COI website and select, “What are the PHS agencies and other sponsors that have adopted the PHS regulations?”.
If the subrecipient does not have a compliant PHS policy, the DBO provides the subrecipient with the Yale model PHS compliant policy and model COI disclosure form for the subrecipient to adopt and complete.
Subrecipient Cost in Yale’s Budget
The PI must integrate the subrecipient’s scope of work into the proposal, and include the total amount of the subrecipient’s budget (including the subrecipient’s F&A) as a direct cost line item in the budget. When calculating the Yale budget, it is important to take into account the prime sponsor’s written policy if it deviates from Yale’s standard practice of charging F&A on the first $25,000 of each subaward. Please note this formula only applies to federal sponsors. Application of this formula to a budget under any other type of award may require a cost share waiver (check with your proposal manager to determine if a cost share waiver is necessary). Many non-profit foundations have written policies which assess lower indirect cost rates to awards, including subawards.
Issuing subawards that were not proposed (after the fact)
Throughout the life of an award, a situation may arise in which a portion of the research must be carried out by a subrecipient that was not part of the original proposal. If the prime award has been received by Yale, the sponsor’s requirements should be reviewed and the OSP Award/Contract Manager should be contacted to determine if prior sponsor approvals to add a subaward is required (especially for foreign subawards, whether first or second tier). The Award/Contract Manager will determine the necessary approval process according to the prime award and will advise accordingly.
The department business office should obtain from the subrecipient a completed SIC form or FDP Letter of Intent (LOI), scope of work, budget and budget justification and email them to the assigned GCAT mailbox. The email should contain the Yale PI’s name, IRES record number and grant/contract ID. An activity log will be opened to the Award/Contract Manager to review the subrecipient documents and if approved, will log the new subaward to the Subaward Manager for processing, including creating the new subaward grant lines and supplier contract in Workday.
Subaward Initiation and Setup
Prior to issuing a subaward, the Subaward Manager will review and confirm that all required subawardee documents and certifications have been received. The Subaward Manager will contact the business office to secure any needed documents or information that is missing or incomplete, such as:
- IRB/IACUC protocol approval, and
- Certification that the subrecipient adopted its own PHS FCOI policy
OSP will not issue a subaward until all compliance requirements are in place. In addition, the Subaward Manager will conduct a financial audit check based on OMB Uniform Guidance (2 CRF 200, Subpart F) or other financials if the subrecipient is not subject to the Single Audit. When all compliances are in place and financial documents have been received, the Subaward Manager will complete a risk assessment of the subrecipient entity.
Uniform Guidance requires a risk analysis be completed by Yale to evaluate the likelihood that a subrecipient will fail to comply with the terms and conditions of the subaward. OSP assesses the subrecipient’s financial status and internal controls prior to issuing a subaward. This is completed during the issuance process and it is monitored 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, we will contact the subrecipient to obtain a copy of their audit or ask that they complete a financial questionnaire to complete the risk analysis.
Based on our evaluation, OSP determines the appropriate monitoring strategy which is reflected in the terms and conditions of the subaward agreement. If the assessment identifies areas of concern, OSP in consultation with the PI and DBO, will determine an appropriate risk mitigation strategy/plan.
The Subaward Manager will draft the subaward agreement determining the most appropriate type of agreement mechanism, flowing down all applicable prime award terms. Negotiation of the subaward terms may be necessary and may require PI and business office involvement. Upon final agreement between Yale and the subrecipient the subaward will move forward with full execution by the institutions.
Subaward actions requiring prior approval
If carry over authority is not automatic and requires sponsor approval, an Authorized Official of the Subrecipient institution should submit a written request for carry over to the Administrative Contact noted in the original subaward agreement (typically the OSP Subaward Manager.) The request will be forwarded via email to the DBO for review. If the DBO and PI concur, a written prior approval request incorporating the Subrecipient’s request should be sent to the assigned GCAT mailbox and will be assigned to the OSP Award/Contract Manager for review and submission to the sponsor in accordance with 1307 PR.01 Establishing Subrecipients Associated with Sponsored Programs Section 4D: Subaward Renewals and Modifications.
A Subrecipient’s carry over request to Yale should include:
- Amount of carry over after commitments
- Reason for carry over
- Summary of how carry over funds will be s
- Detailed budget
- From and to dates of carry over
Once the sponsor approves the carry over, the OSP Award Manager will log a subaward amendment to the Subaward Manager to authorize the carry over.
If carry over is automatic, there is no need to obtain approvals or specify carry over amounts in subsequent subaward amendments.
No Cost Extensions
An Authorized Official of the Subrecipient institution should submit a written request for a no cost extension to the Administrative Contact noted in the original subaward agreement (typically the OSP Subaward Manager.) A Subrecipient’s extension request for federally-sponsored projects should be made no less than 30 days prior to the end date, or in accordance with the terms and conditions of the subaward agreement if privately sponsored. Upon receipt, the request will be forwarded to the DBO for review.
If the DBO and PI concur, an approval for an extension of the subaward end date should be emailed to the Subaward Manager. The email should contain the following:
- PI name, sponsor name, sponsor ID, IRES record number, current expiration date, new requested expiration date.
- Programmatic reason for an extension.
- Confirmation that sufficient funds are available to support the project for the extended period of time and for the approved/committed effort.
If the Subrecipient requested an extension directly from the Yale PI, the DBO should email the extension approval to the Subaward Manager.
Additional funding and time
During the life of a subaward, there may be circumstances that require an amendment to authorize additional funding or adjust the period of performance. In these cases, the DBO must send an email containing the request to the assigned GCAT mailbox and OSP Award/Contract Manager. The email should contain the Yale PI’s name, IRES record number, grant/contract ID and an explanation of the programmatic reasons for an amendment. Also provide the budget amount, effective dates and whether the Subrecipient is compliant with invoicing, reporting and performance requirements. The OSP Award/Contract Manager will review the request and if approved, will log the amendment to the Subaward Manager for processing.
At the time a notice of award for a continuing year is received and an activity log is opened to the Subaward Manager to process an amendment, the Subaward Manager will email the DBO for confirmation of the budget, and compliance with invoicing, reporting and performance requirements.
- 1307 PR.02 Managing Subrecipient Activity Associated with Sponsored Programs
- 1307 PR.03 Monitoring Subrecipient Activity Associated with Sponsored Programs
OSP, the DBO and PI monitor subrecipients to ensure:
- that the subaward is used for authorized purposes in compliance with federal regulations, as well as sponsor and Yale requirements and
- that subaward performance goals are being met.
PIs and business offices have a role in subrecipient monitoring by ensuring progress reporting and invoicing requirements are being met according to the terms and conditions of the subaward agreement.
Progress Reporting: The principal investigator monitors the technical progress of a subrecipient’s performance as defined in the scope of work of the subaward. The PI should notify the business office and/or OSP of any performance issues with the subrecipient.
Invoicing: The PI (or delegate) reviews the invoice for reasonableness, that all costs appear appropriate, and the subrecipient is making adequate progress toward the aims of the subaward. The department business office reviews invoices for adherence to the budget and terms and conditions of the related subaward, monitors the status of invoices to ensure timeliness and accuracy of payments, and monitors the remaining balance of the subaward to ensure timeliness of invoice submission by the subrecipient.
- Invoices should not be processed for payment until a fully executed Subaward has been activated in Workday.
- Always run the “Find Subawards – Yale” report to determine if there are sufficient funds remaining to pay an invoice. Do not approve an invoice for payment if the Remaining Balance on the Supplier Contract will not cover the total amount invoiced.
- Do not approve an invoice for payment if the invoice includes unallowable costs, or if expenses charged are not part of the subrecipient’s budget in the subaward agreement.
- If an invoice is submitted by the subrecipient after the contractually required invoicing timeframe in the subaward, Yale may elect to not pay the invoice. Yale needs to pay invoices before the sponsor’s required reporting/payment timeframe and within Yale’s accounting closeout timeframe to ensure recoupment of funds. Untimely invoicing may also result in the increase of the subrecipient’s risk level.
- Run the Subaward Invoices in Progress–Yale report to see invoices that are Aging at 0-10 days, 11-20 days, 21-30 days, and 31+ days. 2 CFR Part 200, Uniform Guidance requires Yale to pay subrecipient invoices issued under a federal prime award within 30 calendar days after receipt of the invoice unless the invoice is believed to be improper.
- Use the Subaward Invoice Review Checklist to assist with your review of subaward invoices.