The first step in setting up a new subaward is for the PI/PD and department administrator to review the funding and finalize the budget. Once the budget is finalized, the PI/PD and department administrator may complete a Subaward Order Form and submit the request to their Research Subcontracting contact on the Sponsored Projects team. The Scope of Work, Detailed Budget, and Budget Justification documents should be included with the order form. 

Submitting the Subaward Order Form request initiates the subaward process with Sponsored Projects Research Subcontracting, which includes subrecipient monitoring and drafting the subaward agreement.

• Subaward Order Form (PDF)
• Subrecipient Profile Questionnaire (PDF)
• Contact Research Subcontracting

Under federally funded grants and cooperative agreements, Brown has a responsibility to conduct subrecipient monitoring throughout the award period of performance.

There are two distinct elements of the subrecipient monitoring process:

1. A risk assessment of the subrecipient institution
2. An ongoing review of the subrecipient’s performance

Risk Assessment

Subrecipient monitoring takes place throughout the life of a sponsored project. Information is gathered at the proposal and award stages, as well as during an annual review process to evaluate the subrecipient institution’s risk of noncompliance with federal regulations. This institutional risk assessment is completed by the Research Subcontracting team upon receipt of proper documentation from the subrecipient organizations. The University is required to verify subrecipient eligibility to receive federal funding and to manage high-risk subrecipient collaborations. 

Required Documentation

If the proposed subaward is the first time that the University has collaborated with the subrecipient institution, then an initial subrecipient monitoring process will require the following documentation:

• Either an active profile on the Federal Demonstration Partnership (FDP) Expanded Clearinghouse or a completed Subrecipient Profile Questionnaire
• A copy of the subrecipient institution’s most recent Single Audit, audited financial statement or other similar financial documentation — if this information is unavailable, the subrecipient institution is required to provide additional explanation
• A copy of the subrecipient institution’s most recent Indirect Cost Rate Agreement, if applicable

Unique Entity Identifier

If the subaward is funded under a federally sponsored project, the subrecipient institution is required to have an assigned Unique Entity Identifier (UEI) in SAM.gov. For an organization to qualify as a subrecipient, the organization is not required to maintain a full active SAM.gov registration, only to have an assigned UEI.

If this is the first time that a subrecipient institution is receiving federal funding, it may be likely that the subrecipient organization will need to submit a new UEI request to SAM.gov. This process may take anywhere from a few business days to a few weeks, depending upon the subrecipient institution’s ability to process such a request.

Factors to Consider

When conducting the subrecipient risk assessment, the Research Subcontracting team considers several factors, including but not limited to: 

• Location, size and age of the organization
• Amount of the subcontract and percentage of the prime award being subcontracted
• For-profit status of the organization
• Level of prior experience working with Brown

Additionally, the Research Subcontracting team screens subrecipient institutions and subrecipient PIs through the Visual Compliance database to determine if there are any restrictions on the institution or the individual from receiving federal funding.

Foreign Subrecipient Institutions

If the proposed subrecipient institution is a foreign organization, and it is the first time that the University has collaborated with that institution, the Sponsored Projects team strongly recommends that the PI/PD or department administrator contact the subrecipient organization at the time of proposal submission to start obtaining the required subrecipient monitoring documentation as early in the process as possible. The lead time for foreign organizations to provide this documentation and to complete SAM.gov registration for a UEI can be significant.

Ongoing Review of the Subrecipient’s Performance

During the term of a subaward, the PI is responsible for monitoring the activities of subrecipients, as necessary, to ensure that federal awards are being used for their authorized purpose and that performance goals are achieved. This monitoring is performed on a regular basis through such activities as regular communications with the subrecipient, interactions at technical meetings, review of progress reports and review of invoices.

The invoice review process is a critical component of the ongoing subrecipient monitoring process as it provides an opportunity to address concerns prior to disbursement of funding. Brown’s standard subaward template requires the subrecipient to submit invoices at least on a quarterly basis, and not more frequently than monthly. The subrecipient is required to submit the invoices directly to the financial contacts — department administrators and PI/PD — for the project. 

Once the PI/PD has completed the invoice review process, and has approved the invoice for payment, the department administrator may receive the invoices in Workday for payment.

As the prime award is modified by the sponsor, the project may require a modification to the subaward agreement as well. Subaward modifications are used to extend the period of performance, to increase the funded amount and/or modify other terms and conditions as needed throughout the life of the subaward. 

To request a modification, the PI/PD and department administrator may submit a change order request to the supplier contract in Workday. The change order request should include a completed copy of the Subaward Modification Form, which provides the details of the modification request. If there are any other supporting documents for the modification, these should also be attached to the change order request.

Subaward Modification Form (PDF)

Under the Federal Funding Accountability and Transparency Act (FFATA), the University is required to complete reports for all active subawards issued under federal grants, cooperative agreements and federal contracts. The Research Subcontracting team in Sponsored Projects is responsible for submitting these subaward reports.

If the subaward has ended and the PI/PD has received all technical reports, and if the final invoice from the subrecipient has been reviewed, approved and paid, then the PI/PD and department administrators should close out the subaward, even if the overall project is continuing into subsequent periods of performance or a no-cost extension.

The PI/PD should complete the Subaward Closeout Certification Form and submit a copy to their Research Subcontracting grant and contract administrator and to their Post-Award grant and contract accountant.

• Subaward Closeout Certification Form
• Contact Sponsored Projects