What is a subaward?
Uniform Guidance defines a subaward accordingly, “an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.” In this context, the “pass-through entity” is Montclair State University and the “subrecipient” is another institution or organization, for example, another university. Subawards can be part of a federal, state or private award. The “legal agreement” is typically called a subaward agreement which includes the subrecipient’s scope of work, budget and flows-down the required terms/conditions of the award to Montclair State University, e.g. reporting requirements, prior approvals, etc.
What is the subaward process?
When Montclair State University is providing a subaward to an institution, Uniform Guidance requires a risk assessment take place. As the prime awardee, Montclair is responsible for the subrecipient’s subaward actions. Consequently, the Office of Sponsored Programs (OSP) will first conduct a risk assessment to determine the level of risk involved with entering into a subaward agreement with a subrecipient. For example, OSP will determine if the subrecipient has any prior Single Audit findings. Once the risk assessment is completed, OSP will draft the subaward agreement and provide it to the subrecipient for review, and/or partial execution. If there are terms that the subrecipient would like to negotiate, OSP will do so. Once a subaward agreement is fully executed, OSP will inform the Office of Grant Accounting who will encumber the subaward budget in Workday as appropriate. During the life of the subaward agreement, the PI will review invoices submitted by the subrecipient, typically on quarterly basis. The PI should review the invoices with the following questions in mind:
- Are the subrecipient expenses consistent and reasonable with the technical work completed to date?
- Is the subrecipient current with all non-financial deliverables due by the invoice date?
- Is the subrecipient current with all technical/programmatic reports due by the invoice date?
If the PI approves the invoice, the assigned Grant Accountant will release payment to the subrecipient institution. If the PI does not approve the invoice, he/she should discuss with his/her Co-PI at the subrecipient institution and inform the assigned Grant Accountant.
For more information contact, please contact Catherine Bruno, Senior Post-Award Officer at brunoc@6317p.com or at 973-655-6923
Updated: May 17, 2024