Once the categorization of the collaborator has determined that you are working with a subrecipient, there is a series of processes that must be followed in order to comply with federal regulation and Syracuse University procedures.
Initial Subaward Setup
The PI submits a Request to Issue a Subaward form to OSP. This document is used to start the process of executing an agreement with a collaborator at another institution.
- It must include:
- Third-Party Engagement Form
- Statement of Work
- Budget/Narrative
- Appropriate indirect costs
- Approved rate vs. De minimus rate of 10%*
- Current Contact Information
- An abstract of the work to be performed by the collaborator.
This request triggers the University’s Subrecipient Monitoring processes.
- Principal Investigators (PIs) have primary responsibility for monitoring a Subrecipient’s technical and financial performance to ensure compliance with both prime sponsor and subrecipient subaward terms/conditions.
- Guidance for the PI can be found in the PI Quick Guide to Subrecipient Monitoring
- OSP conducts Subrecipient Monitoring activities to ensure compliance with federal requirements and SU subrecipient monitoring processes.
- Process includes the review of:
- Entity documents are used to evaluate any risks associated with engaging them on a sponsored project.
- Documents include the Subrecipient Profile, Single Audit, Federally Negotiated Rate Agreements, Financial Statements as applicable
- Past experience with the entity. Past experience including accuracy and timeliness of invoicing, compliance with deliverable requirements and quality of work are considered when identifying risk.
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- Entity documents are used to evaluate any risks associated with engaging them on a sponsored project.
- The identified risk will be used to determine specific risk mitigation strategies that can be written into the subaward agreement.
- Process includes the review of:
- The PI and the Office of Sponsored Programs understands that failure to adequately monitor the compliance of subrecipients could result in damage to Syracuse University’s reputation and has the potential to jeopardize current and future funding.
- It is the responsibility of the PI and the Office of Sponsored Programs on behalf of Syracuse University, as the pass-through entity, to ensure the good stewardship of sponsored funding.
Subaward Agreement is Issued
- OSP will draft, negotiate and execute the subaward agreement.
- Copies of the agreement will be forwarded to the PI and Department Administrator when finalized.
- Subaward agreements determine the rules for managing your collaborator.
Subaward Modification
As work progresses, there may be a need to make changes to the subaward agreement. Whenever a change is needed, the PI must submit a Request to Modify Subaward to OSP. The following are things the PI should think about when changes are to be made:
- Do you want to continue collaborating?
- Is the work progressing according to plan?
- Have invoices been submitted in a timely manner and are they appropriate?
- Are compliance issues in order?
- Are reporting requirements sufficient?
- Who is authorized to approve?
Invoices
As work continues the subrecipient will submit invoices for payment. Subaward agreements require that invoices be submitted directly to OSP for contractual review. Once approved by OSP invoices will be forwarded to the PI for approval. The Principal Investigator/Project Director (PI/PD) is responsible for reviewing regularly submitted invoices to ensure that expenditures are reasonable in the context of work performed, progress is being made and to confirm that all required progress reports or deliverables are up-to-date, as required by the statement of work or terms of the subaward.
- The OSP review of subrecipient invoices specifically:
- Confirms invoice submission is in accordance with requirements of the executed subaward.
- Confirms invoices includes signature & certification statement
- Confirms invoices details time periods which expenses were incurred
- Confirms invoices format includes current period costs, cumulative costs and cost share (if applicable)
- Confirms expenses have been distributed to major categories (not a one line invoice)
- Confirms cumulative expenditures do not exceed the total amount of the subaward
- Confirms expenses are reasonable, allocable, and allowable with respect to the award terms
- Confirms budget deviations are allowable and within the requirements of the subaward
- Confirms, if applicable, cost share commitments are met
- Confirms F&A costs have been calculated correctly
- Prior to requesting PI/PD review, OSP will address any missing/incorrect information or unallowable expenses. The subrecipient will be contacted directly for additional supporting documentation or any other necessary resolution. Additionally, invoices that are not compliant with the executed agreement’s guidelines will also be returned for correction.
- While OSP does a preliminary review of subrecipient invoices, it remains the PI/PD’s responsibility to review invoice details to confirm that all the above items are complete and accurate. In addition, the PI review of subrecipient invoices is contextual and grounded in his/her familiarity with the subrecipient’s statement of work, awarded budget, and reporting requirements.
- All concerns or inconsistencies should be raised directly with the collaborator and/or OSP. A satisfactory resolution is required prior to approving any questioned invoice.
- Special attention should be given to Subrecipients who do not invoice regularly. Regular invoices provide information to the PI regarding the ongoing work. The lack of timely invoicing is an indication that work is not progressing which may put the success of the entire project in jeopardy.
When the PI communicates approval to OSP, the invoices will be forwarded for payment.