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Subaward Agreement Issuance

ORA Confirmation of Subaward Agreement Information

When we receive the prime award at ORA, we start a subaward file. The award issued to the subrecipient is dependent on the terms of the prime award and the risk analysis results we compile.

After reviewing the prime award, the ORA Subaward Officer will contact the University principal investigator (PI) and/or department administrator, and/or Subrecipient PI and/or administrative contact as needed to confirm or request the following information regarding the subaward:

  • Period of performance—may not be outside of the University’s period of performance for the prime award, but may be issued for a shorter period than the prime award term.
  • Statement of work
  • Budget (including cost share, if applicable) and budget justification
  • Technical and financial reporting requirements
    • A best practice is to require reports to adequately monitor progress and fulfill reporting requirements to the sponsor. For example, for awards with an annual and final progress report requirement, the UM PI should consider requiring the subrecipient to provide an annual and final progress report covering their portion of the project to the UM PI, the progress report should be provided in sufficient time to allow the subaward information to be incorporated into UM’s progress report to the sponsor.
    • UM PIs should remember that requesting increased reporting increases their administrative burden and that of their department as they become responsible for ensuring that all required reports are received, reviewed, and their acceptability documented.
  • Verification that subrecipient is compliant with IRB, IACUC, and IBC approvals (if applicable)
  • Subrecipient’s contact information
  • Other information as needed
  • Approval of funds to carryforward between budget periods (if allowed by prime)

Risk Analysis & Compliance Review

Uniform Guidance, 2 CFR 200.331, Requirements for pass-thru entities, requires a risk analysis be completed by the UM to evaluate the subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. We will do this during the issuance process and monitor it 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, ORA Subaward Officer may contact the subrecipient to obtain a copy of their audit or may be asked to complete a Financial Questionnaire to complete the risk analysis. If the subrecipient is using the UM’s FCOI policy, they will need to complete online FCOI training and will need to provide a disclosure form annually.

ORA Subaward Officer will complete reporting in accordance with the Federal Funding Accountability and Transparency Act (FFATA) which requires that the UM reports federal subawards it issues over $30,000.

ORA Subaward Officer will also conduct a suspension and debarment check and a review of the F&A rate agreement.

Agreement Negotiation & Execution

The subrecipient may want to negotiate changes or request clarification of the terms and conditions of the subaward. ORA Subaward Officer will negotiate these changes with the subrecipient, and seek approval from PI and/or department personnel as needed.

Once the subaward is signed by the subrecipient and ORA, a copy of the fully executed subaward will be sent to the PI via email. The subaward funding will be encumbered in MarketPlace and the General Ledger (GL) after the subaward is fully signed.