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A subaward is a formal written agreement made between the University of Maine and another legal entity (subrecipient) for programmatic activity under a University sponsored project. For more information on Subawards please see the University of Maine Administrative Practice Letter on Subrecipient Monitoring (section VIII-D) and Uniform Guidance at 2 CFR 200.330 Subrecipient and Contractor determinations.

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  • A defined portion of a sponsored project is assigned to another entity
  • The subrecipient assumes full responsibility, including intellectual leadership, for completing the assigned work
  • Work is generally performed by the subrecipient’s personnel (including graduate students) using their resources (usually at their site)
  • The subrecipient must comply with the terms and conditions of the subaward agreement, including terms flowed down from the University’s sponsor
  • A subrecipient will need to obtain approvals from their IRB or IACUC if human or animal subjects are used in their portion of the work
  • Subrecipient personnel might be an author or co-author of a paper written about the project
  • An invention might arise from the work performed by the subrecipient

The following is a brief breakdown of roles and responsibilities between the Principal Investigator (PI), the Office of Research Administration (ORA), and the Subrecipient in relation to Subaward Actions:

PI Role & Responsibility

  • Request proposal documents from proposed subrecipient, including any ancillary documents required by UM or sponsor
  • Indicate subawards in Section on PARS
  • Prepare and submit complete proposal to ORA. All subaward documents must accompany proposal even if not required by the sponsor as part of the proposal package. The documents are for ORA’s files.
  • Provide additional information required for subaward issuance
  • Monitor subrecipient technical progress and performance
  • Monitor subrecipient’s adherence to terms and cost sharing requirements
  • Verify compliance approvals are current for subrecipient’s portion of statement of work (human subjects, animal subjects, biosafety)
  • Monitors receipt of invoices and reviews that expenses are aligned with technical progress and all required reports are received
  • Reviews invoices via email from umsubawards@maine.edu
  • Assesses need to modify statement of work or budget
  • Plans for timely closeout and obtain prime no cost extension if needed (follow up on missing reports, receipt of final invoice and release of claims form)
  • Promptly alerts ORA Subaward Officer when problems arise (inability to obtain satisfactory invoice, nonperformance)

ORA Role & Responsibility

  • Review and submit proposal
  • Negotiate with sponsor and accepts prime award
  • Follow up with PI/Dept to obtain any additional required documentation/data required for subaward
  • Review risk levels and, if necessary, modify subaward agreements
  • Prepare, negotiate, issue and distribute subaward agreement
  • Collect, maintain, and report FFATA data
  • Activate/encumber subaward funds in PeopleSoft/Marketplace
  • Assist PIs and departments with monitoring subawards
  • Request and review annual audit reports
  • Verify corrective action plans are implemented (if necessary)
  • Receive, track and pay invoices with PI approval
  • Prepare, negotiate, issue and distribute amendments
  • Modify subaward encumbrances in the financial system
  • Complete closeout
  • Help resolve problems that arise during performance

Subrecipient Role & Responsibility

  • Provide proposal materials to PI/department within stipulated deadlines
  • Create and or agree on work scope and budget
  • Provide compliance approvals and risk assessment information (e.g., human subjects, biosafety, audit reports, financial questionnaire and supporting financial documentation)
  • Prepare and submit technical progress and all required reports to UM PI
  • Prepare and submit invoices to Subawards email box, umsubawards@maine.edu for review and processing
  • Assess need to modify statement of work or budget and work with ORA Subaward Officer to obtain prior approvals as needed

It is important to correctly determine whether an entity should be considered a subrecipient or a subcontractor, so that the appropriate terms and conditions are applied and budget calculations are performed accurately.

A subaward is likely appropriate if you can answer “yes” to any of the following questions:

  • Does the entity’s scope of work represent an intellectually significant portion of the programmatic effort of the overall project?
  • Does the entity have responsibility for programmatic decision making?
  • Could the entity’s work result in intellectual property developed or publishable results (including co-authorship)?
  • Will the entity need animal and/or human subjects approval for its portion of the work?

An entity would be considered a contractor if they provide goods or services within normal business operations to many different purchasers and operates in a competitive environment.

For additional guidance on determining if work conducted by an institution or organization outside of the University should be procured under a subaward or a different mechanism, such as a Contract for Professional Services, see the FDP Checklist to Determine Subrecipient or Contractor Classification.

Services not requiring a subaward may be covered by the purchasing procedures of the University of Maine Administrative Practice Letter for Procurement (section VII-A) or contact your project’s ORA Pre Award staff member for additional guidance via proposals@maine.edu.

Check out the Subaward Toolkit for more helpful resources. If you don’t see an answer to your question there, don’t hesitate to contact ORA’s Subaward Team for more guidance at umsubawards@maine.edu.