Steps for Setting Up An Outgoing Northeastern Issued Subaward:
Note: If your subaward is incoming from another institution (i.e. Northeastern is the subrecipient), please contact your ORAF Grant Officer for set-up instructions.
1. Complete the Subaward Request Form.
a. Be sure to always attach a Statement of Work (SOW) and Line Item Budget with a Budget Justification.
Please note that Northeastern normally issues subawards in one year increments. Therefore, the subrecipient period of performance and cumulative incremental funding will be extended by yearly modifications.
2. Submit the Subaward Request Form, signed by the Northeastern PI, to:
Office of Research Administration & Finance
490 Renaissance Park
The subaward agreement will be drafted by the Subawards Office and sent to the subrecipient for review, negotiation, and signature. The subaward will then be reviewed and signed by ORAF.
A PO/Encumbrance will be generated by the Subawards Office. The encumbrance (reserved funding) will reside in your grant budget. Account numbers 78050 through 78059 are used for subawards. Please contact Dan Gilbert if you would like to know more about how subawards are setup in your grant using the Northeastern accounting system.
Invoices from the subawards will first be sent to the Subawards Office for review and then to the PI for additional review and signature. After signature, the PI will send the signed invoice back to the Subawards Office for Accounts Payable processing. Please note that Northeastern is a net 35 institution i.e., a check will be disbursed from the Accounts Payable Office 35 days after the invoice date.
Subrecipient invoices must be based on actual expenses incurred by the subrecipient unless noted otherwise in the subaward agreement.
The Northeastern PI must approve all subaward invoices to attest that all subrecipient charges appear reasonable and the progress to date on the project is satisfactory.
If your subaward is more than one year in length, a subaward amendment will be needed. Please submit a Subaward Request Form for year two of the subaward (and for each subsequent year) approximately one month prior to the year two start date if possible. Be sure to include the year two line item budget and SOW (if different from year 1).The subaward amendment agreement with the cumulative subaward dollar amount will be drafted by the Subawards Office and sent to the subrecipient for review, negotiation, and signature. The subaward will then be reviewed and signed by ORAF. The PO/Encumbrance will be modified by the Subawards Office to reflect the new subaward amendment amount.
- The period of performance of a subaward cannot start earlier or end later than the period of performance of the main grant award.
- Prior approval will be needed from Northeastern (and possibly from the Sponsor) for: changes to the the scope of work; a new principal investigator; change in period of performance; significant changes to the budget.
- A final report of expenditures must be submitted to Northeastern normally within 60 days (or as otherwise stated in the subaward agreement) of the period of performance end date.
- Conflict of Interest. Northeastern PI and subrecipient PI must disclose any financial interests that could pose a conflict with their professional obligations to the University before a subaward is issued. Investigators who apply for or receive PHS (Public Health Service) funding must now adhere to new Financial Conflict of Interest (FCOI) regulations. Please be advised that ORAF is unable to process new proposals or awards for PHS funded researchers until the required training and disclosure are completed. Please visit: http://www.northeastern.edu/research/raf/fcoi/ for more information.
- Monitoring. All subawards require risk assessment and monitoring to ensure that they comply with Federal regulations and with the awarded subaward terms. In addition, the subrecipient will be asked annually to provide their most recent financial audit as part of the monitoring process.
- Closeout. Please remind each of your subrecipient to submit a final invoice, final progress report, and final invention statement (if any) within the time period stated in the subaward agreement. Final invoices must be paid before the grant closes. Make sure that any remaining PO encumbrances are removed from the grant budget prior to close. An ORAF Financial Analyst will send a comprehensive Grant Closeout Checklist to you several weeks prior to the grant end date.
2 CFR §200.330 Subrecipient and contractor determinations.The non-Federal entity may concurrently receive Federal awards as a recipient, a subrecipient, and a contractor, depending on the substance of its agreements with Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. The Federal awarding agency may supply and require recipients to comply with additional guidance to support these determinations provided such guidance does not conflict with this section.(a) Subrecipients. A subaward is for the purpose of carrying out a portion of a Federal award and creates a Federal assistance relationship with the subrecipient. See §200.92 Subaward. Characteristics which support the classification of the non-Federal entity as a subrecipient include when the non-Federal entity:(1) Determines who is eligible to receive what Federal assistance;(2) Has its performance measured in relation to whether objectives of a Federal program were met;(3) Has responsibility for programmatic decision making;(4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and(5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.(b) Contractors. A contract is for the purpose of obtaining goods and services for the non-Federal entity's own use and creates a procurement relationship with the contractor. See §200.22 Contract. Characteristics indicative of a procurement relationship between the non-Federal entity and a contractor are when the non-Federal entity receiving the Federal funds:(1) Provides the goods and services within normal business operations;(2) Provides similar goods or services to many different purchasers;(3) Normally operates in a competitive environment;(4) Provides goods or services that are ancillary to the operation of the Federal program; and
(5) Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar requirements may apply for other reasons.
(c) Use of judgment in making determination. In determining whether an agreement between a pass-through entity and another non-Federal entity casts the latter as a subrecipient or a contractor, the substance of the relationship is more important than the form of the agreement. All of the characteristics listed above may not be present in all cases, and the pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract.
For questions or clarification about the subaward process, please contact Dan Gilbert at email@example.com or 617-373-2127.