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Business Office Responsibilities
Principal Investigator Responsibilities

Carleton College is responsible for ensuring that all subrecipient/subaward agreements the College issues comply with federal regulations. In so doing, the appropriate College faculty and staff must monitor the use of funds received and confirm their use in accordance with applicable laws, regulations, and the terms of the award.

See also the Business Office’s Subaward Management page.

Any subaward issued by the College on a federal grant must contain ALL required elements identified by 2 CFR §200.331, and must also generally include provisions (as outlined Prospective New Awardee Guide) for

  • Statutory requirements such as non-discrimination, drug-free workplace, animal rights, human subjects, and any applicable grant terms and conditions,
  • Any additional requirements necessary in order for the pass-through entity to meet its own responsibility to the federal awarding agency (such as, timely submission of financial, technical, and performance reports),
  • The indirect cost rate(s) and base(s) approved for use on the subaward,
  • Audit requirements and the pass-through entity’s access to records
  • The pass-through entity’s right to conduct technical and administrative site visits,
  • Termination clauses and/or legal remedies for non-performance, and
  • Closeout procedures (when the subaward is completed).

Business Office (BO) responsibilities

per uniform guidance (2 CFR §200.331(d), (f), (g) and (h)) 

Before or at time of issuing subaward

  • determine, with PI, role of subaward vs. contract, using checklist (below, PI responsibilities)
  • obtain subawardee contact information and send to subrecipient institution
    • Contact sheet
    • Subrecipient Information Form (that asks for audit report, F&A rate, and more)
  • do a merit, integrity, and risk assessment of the sub-recipient based primarily on results of audits, but also prior experience, new personnel or substantially changed systems, results of federal monitoring
    • conduct status checks for vendor, terrorist, debarment or suspension via the System for Award Management (SAM
    • check FAPIIS to rule out “not qualified” status, if subaward is greater than $150,000 (in accordance with Duncan Hunter Act Section 872) [Jan 2016 find FAPIIS at SAM]
    • verify single audit compliance
    • complete the Risk Assessment Questionaire and keep with file
  • ask for statement of work (and possibly a letter of commitment), budget, budget justification
  • draw up Subaward Agreement, “FDP Cost Reimbursement Research Subaward Agreement” (face page) and attachments, to include the following data elements:
    • Subrecipient name (which must match registered name in DUNS) & DUNS number
    • Federal Award Identification Number (FAIN)
    • Federal award date
    • Subaward period of performance start and end date
    • Amount of federal funds obligated in this sub action
    • Total amount of federal funds obligated to the subrecipient
    • Total amount of the federal award
    • Federal award project title or description
    • Name of federal awarding agency, pass-through entity and contact information for awarding official
    • CFDA number and name (including the dollar amount made available under each award and the CFDA number at time of disbursement)
    • Subaward number (use Carleton account/allocation number plus subawardee abbreviation)
    • Identification of whether the award is R&D
    • Indirect cost rate information (using subawardee negotiated rate with government or with pass-through, or 10% de minimis rate)
  • include attachments or documents as needed
    • Cover letter with explanations, tailored to subrecipient
    • Attachment 1: Research Subaward Agreement Certifications and Assurances
    • Attachment 2: Research Subaward Agreement Prime Award Terms and Conditions – NSF
    • Attachment 3: Research Subaward Agreement Pass-through Entity Contacts (3A), Research Subaward Agreement Subrecipient Contacts (3B)
    • Attachment 4: Research Subaward Agreement Reporting Requirements
    • Attachment 5: Cost Reimbursement Research Subaward Agreement (Statement of Work, Budget, Budget justification)
    • Vendor ACH Authorization Form and W9 form
  • email subaward agreement and attachments with cover letter instructing recipient to send back the signed copy and completed documents requested/applicable
  • have award document signed by Carleton Comptroller and return final copy to subrecipient
  • compile and distribute subrecipient documents
    • compile audit report/certification, IDC letter, fringe benefit agreement or URL, and completed “Subrecipient Information Form” in file
    • send copy of final award document to SERC (or faculty PI, as appropriate)
    • give W9 and ACH authorization to Accounts Payable

After subaward has been issued 

  • file via the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) to meet FFATA reporting requirements on sub-awards > $25,000 (or multiple awards totaling > $25,000) for new Prime grants effective 10-1-2010 and after
  • monitor subrecipient’s progress and performance, and document any contacts with sub, whether routine or more involved (i.e., technical or administrative site visits)
  • review performance reports with PI to ensure work effort matches subaward statement of work
  • review financial reports (invoices) and verify that
    • charges are allowable, allocable, and reasonable
    • expenses were incurred during the period of performance of the subagreement
    • there is an available balance to cover the invoice amount
    • the correct encumbrance number is being used on the invoice
  • ensure these elements are included in all subrecipient invoices
    • Project name
    • Carleton project number
    • Approved budget lines
    • Current period expenditures by line item
    • Total expenditures to date
    • Balance due
    • Remaining balance
    • Fiscal agent certification
  • request that this language be used on subrecipient invoices/financial reports

“By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements, and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil, or administrative penalties for fraud, false statements, false claims or otherwise. (U.S. Code Title 18, Section 1001 and Title 31, Sections 3729-3730 and 3801-3812).”

  • monitor payment to subawardee so as to not exceed total agreed budget amount
  • send form (Mar/Apr annually) to subrecipient asking for their UG audit compliant certification (previously A-133 audit) for each year that the subaward is active
  • draw up and send modifications: amendments or extensions as necessary, with approval by PI (send Subcontract Modification Form to subawardee)
  • issue management decisions: ensure corrective action on any deficiencies, or consider whether adjustments or enforcement actions are needed

Principal Investigator (PI) responsibilities

Before or at time of issuing subaward 

  • complete checklist to determine subrecipient vs. contractor relationship (characteristics from §200.330)

Subrecipient relationship: check all that apply.

□   An assistance relationship: subaward is for the purpose of carrying out a portion of the federal award project

□   Performance measured against federal program objectives

□   Responsible for programmatic decision-making

□   Adheres to applicable federal program requirements

□   Uses federal funds to carry out a program for a public purpose specified in statue, as opposed to providing goods or services for the benefit of the pass-through entity

Contractor relationship: check all that apply.

□   A procurement relationship: contract is for the purpose of obtaining goods or services

□   Provides goods and services within normal business operations

□   Provides similar goods and services to many purchasers

□   Normally operates in a competitive environment

□   Provides goods or services that are ancillary to the federal program

□   Not subject to compliance requirements of the federal program

As Project Investigator on this prime grant, based on the criteria above, I determine that the award is a _____ subrecipient relationship or ______ contractor relationship.

_______________________________________________________

Dated and signed by Federal grant PI or representative                               

After subaward has been issued

  • document routine contacts with subrecipient and retain documentation
  • track and monitor technical progress of the subrecipient to ensure the efforts outlined in the subagreement scope of work are being met and reimbursements are made in relation to technical progress
    • technical reports can be requested as needed by the PI and should supplement informal communications
    • if there are specific deliverables or reporting requirements, the PI and Business office/CFR staff should include these in the subagreement
    • in some instances a member of the College may make site visits to subrecipient’s place of business
  • document any changes in expectations of work to be done by subrecipient and follow up with the subrecipient PI
    • determine if these changes require an amended contract; all changes in the amount of the subaward or changes in beginning or ending date require an amendment
    • notify the Business Office when an amendment is needed
  • verify all subrecipient’s invoices prior to submission to the Business Office for payment processing
    • if the appropriate technical progress has not been made the invoices should not be approved
    • if the required work has not been done, PI will contact subrecipient and request work be completed
    • invoice will be paid when a suitable agreement for work completion has been determined
  • give special attention to purchases in excess of $3,000 and ask for documents to be provided to show that the subrecipient was in compliance with the price or rate quotation requirements as cited in Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (2 CFR 200.317-326).