Principal Investigator/Department

• Step 1-Review notice of award and solicitation to determine allowability of 3rd parties
• Step 2- Determine whether the collaboration will be treated as a subaward.
  • Refer to “What is the difference between a Subaward, a Consulting/Professional Services Agreement, and a Contractor/Fee for Service Purchase Order?”.
• Step 3- Select subrecipients based on technical expertise and potential ability to perform the scope of work successfully, within the allowable infrastructure of the prime award.
• Step 4- Document the rationale for selection of the specific entity selected, according to sponsor requirements and UI Purchasing policies.
  • Refer to "Initiating a Subaward - Choosing a Subrecipient"
• Step 5- Obtain the budget, budget justification, statement of work, and any other certifications or disclosures required for the proposal.
• Step 6- Verify the proposed subrecipient is on the FDP COI Clearinghouse and if not reach out to the COIR office. 

Principal Investigator/Department

• The PI is responsible for collecting all subaward documentation from all subrecipients and reviewing the documentation for appropriateness.
• Statement of Work: Describe the specific objectives applicable to the subaward.  Provide details of the tasks to be performed (in chronological order) by the Subrecipient within the project performance period. Provide a list of anticipated milestones and due dates if known. The Statement of Work should conform to the requirements of the prime award, such as performance measures required by the prime sponsor.
• Project info: Funding announcement, project title, subaward  project period
• Documents: Letter of intent, biosketches, facilities and resources, letter of support, any funding announcement-specific requirements (e.g., IP letter) as applicable
• Application info: Performance site location, key personnel information, human subjects/vertebrate animals/select agents (if applicable)
• Budget + Budget Justification: Direct costs/year, effort requirement, project-specific expenses
  • The Budget should follow the format required of the funding announcement and correspond to the type of subaward allowed in the funding announcement (e.g., cost- reimbursable, fixed price, or fixed rate/capitation).
    • Allowable indirect cost rate is included for the Subrecipient per the terms of the prime award applicable to the type of work of the Subrecipient.
    • If the funding is federal and a federally negotiated F&A agreement is permitted, documentation of the most current rate is required to be included as an allowable cost.
      • In the event that a current approved federally negotiated F&A agreement does not exist at the time of proposal submission, Subrecipient may utilize the de minimis rate for the project, which is a maximum of 15% MTDC (e.g., capitalized equipment, GRA tuition, patient care costs, and participant support costs). The University of Iowa does not negotiate F&A rates with subrecipients; the limits specified above apply.
• Include the Subrecipient's budget, justification, and statement of work and any other required information in the UI's proposal.
• Include each intended Subrecipient on the UIRIS Routing Form known at proposal stage.
• Outgoing  Subaward Conflict of Interest in Research Form (formerly Form B) If the UI is applying to a sponsor with a conflict of interest in research policy requirement and the Subrecipient is not listed on the FDP FCOI Compliant Entities. 

Conflict of Interest Office (COIR)

• Reviews Subrecipient Questionnaire – Conflict of Interest.
  • COIR verifies subrecipient’s policy complies with the applicable sponsor conflict of interest in research policy.
  • If no policy COIR sends Financial Interest Disclosure Form for subrecipient to complete.
• Notifies DSP when the subaward is approved for compliance with the financial conflict of interest regulation.
• See COIR site for more information.

Division of Sponsored Programs (DSP)

• Review the Routing Form and corresponding application in accordance with investigator and institutional interests, ensuring that:
  • All required approvals have been completed in Workflow.
  • The application has been completed in accordance with sponsor guidelines.
  • The budget calculation is accurate and includes full and appropriately documented costs, including all proposed subawards/subcontracts and the applicable facilities and administrative (indirect) costs as allowed by the sponsor and applicable to the subrecipient/work.
• Confers with COIR office that all COI disclosures are on file prior to authorizing submission.

Principal Investigator/Department

• 	Budget	Budget Justification	Statement of Work	Conflict of Interest in Research Form	Subrecipient Information Form	Compliance Documents (IRB, IACUC, Export Control)	Current Registered Vendor with UI Purchasing	Other as required from the project or sponsor (F&A Rate Agreement, Research Security Training, IT Security)
  	*Ensure no changes in budget and Statement of Work since original proposal
  Subrecipient was included in proposal & routing form	√	√	√	√	√	√	√	√
  Subrecipient is a new	√	√	√	√	√	√	√	√
  	*Check with DSP for prior approval to add Subrecipient to Project

• Prior sponsor approval for subrecipients is required and typically secured by including the subrecipient's scope, budget, and justification in the original proposal. If not included initially, post-award written approval is necessary. The process involves documenting the subrecipient’s unique qualifications, ensuring compliance with 2 CFR 200, and obtaining authorized institutional representative sign-off. Please contact DSP to request prior approval.
• Subrecipient Information Form should be completed for all NEW or Competitive Renewal subawards before submitting the eDSP Subaward Request.
• For more information on the Outgoing Subaward Process, click here
• eDSP OGS Request Module
  • Initiate request through the DSP Research Tracker

  • For more information on completing the request, click here

     

• Review the Subaward Agreement
  • PI/Department will receive an automated e-mail from DSP based on those they select in the OGS module "UI Contact Info"
  • PI/Department is responsible for reviewing subawards terms and conditions to monitor Subrecipient's performance. Any questions or issues pertaining to the terms or performance throughout the subaward should be directed to DSP.
  • Notify dsp-contracts@uiowa.edu if changes are needed.

Purchasing

• Each subrecipient must have a current, approved UI vendor account with UI Purchasing before the outgoing subaward can be issued.
• Reviews the PReq and ensures that the sole source questions are complete
• Upon receipt of the PReq and fully signed subaward, the Purchasing Agent (PA) reviews the Preq, checks contract details and approves the PReq.
• Assigns a Purchase Order (PO) number
  • *If over $25,000.00, the PReq is reviewed and approved by the Director of Purchasing.
• Loads the PReq into PSoft, makes final changes and approves the PO.  The PO dispatch processes run nightly and the following business day the PO is printed.
• Electronically sends the fully executed subaward and PO to subawardee or the original PO documents to DSP

From AP Page:

• AP schedules payment on the PO payment terms and the invoices date.
  • Subaward/PO payments terms are generally "N30."
• If past due invoice is received by AP, the payment will be scheduled to pay 7 days from receipt of the invoice.
• All subaward invoices are required to be received by department before being processed for payment.
• Check is cut/mailed or ACH'd.
• * Note: The Dept and GAO must confirm that a subaward number is completed and ready to close before Purchasing/AP will close the PO.

Grant Accounting Office (GAO)

Reviews the OGS Request to:

• Match the budget to the original budget included in the prime award (if applicable.)
• Conduct a risk assessment and plan monitoring activities based on the results. (see below for additional information).
• Verifies assignment of accounting master file key (MFK) including verifying institutional account 6230 or 6231 distribution.
• Reviews UI Subaward Information Form (FORM I) for audit information and subaward agreement type and any applicable indirect cost rates used.
• GAO review(s) are completed in the OGS system

Risk Assessment

• Subrecipient Monitoring takes place throughout the life cycle of a sponsored project.  Information is gathered at the proposal and award stages as well as during an annual review process to ensure Subrecipient performance of the work and compliance with regulatory requirements. The University is required to verify Subrecipient eligibility and managing high risk Subrecipients. 

Documentation required:

• Subrecipient Profile and Single Audit is available via the FDP Expanded Clearinghouse if Subrecipient participates or the Audit questionnaire portion of the Subrecipient Information Form has been completed by Subrecipient for review.
• Copy of Subrecipient’s federally negotiated indirect cost policy with their federal cognizant agency is provided with OGS request.
• Unique Entity Identifier (UEI) has been assigned and SAM.gov registration is active (as required by the federal award).
• As required by Uniform Guidance, GAO Annually Verifies/Requests and Reviews Subrecipients’ Single Audits
  • Entities not subject to Single Audit are asked to certify the UI Subaward PO#, Federal Assistance Listing Number (aka ALN), and the statement “any and all expenditures of funds from the University of Iowa have been and will be made in accordance with applicable Federal guidance”
  • Documentation of our annual review of Subrecipients must be provided to the State Auditors during UI’s Single Audit 

This information is required to complete a Subrecipient risk assessment prior to issuance of a subaward/subcontract agreement. Some factors that are considered when completing the Subrecipient institution risk assessment includes such factors as the location, size, and age of the organization; the amount of the subcontract and the percentage of the prime award being subcontracted; the for-profit status of the organization; and the level of prior experience working with the UI.

Conflict of Interest Office (COIR)

• COIR receives signed conflict of interest research form from subrecipient that includes all key personnel working on the project. Subrecipient has responded to COIR requests for disclosures and/or trainings as required.
• COIR notifies DSP when the Subrecipient is approved for compliance with the applicable conflict of interest regulation. DSP is then permitted to issue the subaward to the Subrecipient.
• If the subaward is a multiple year project COIR will contact the subrecipient to ask if there are any changes to their disclosure information.

Division of Sponsored Programs (DSP)

• Reviews the OGS Request for completeness and ensures that:

  • The arrangement is appropriately classified as a subaward in accordance with the definition in 2 CFR 200.92 and UI procedures.
  • UI has sponsor approval to issue the subaward.
  • Subaward dates fall within the current funded period.
  • Subaward budget amount and format (including Subrecipient F&A rate and cost sharing, as applicable) within the appropriate limits per sponsor’s policies and the prime award.
  • Appropriate attachments are included as needed
    • Scope of Work
    • Budget & Budget Justification
    • Subrecipient Information Form (for new subawards)
    • Outgoing  Subaward Conflict of Interest in Research Form, if applicable
    • Other (Data Sharing Management Plan, Multiple PI Management Plan, etc.)
  • Works with the Conflict of Interest in Research office for Outgoing  Subaward Conflict of Interest in Research Form review if needed.

  Accounts Payable (AP) & Purchasing

  Reviews Invoices and Processes Payment

• AP schedules payment on the PO payment terms and the invoices date.
  • Subaward/PO payments terms are generally "N30."
• If past due invoice is received by AP, the payment will be scheduled to pay 7 days from receipt of the invoice.
• All subaward invoices are required to be received by department before being processed for payment.
• Check is cut/mailed or ACH'd.

• * Note: The Dept and GAO must confirm that a subaward number is completed and ready to close before Purchasing/AP will close the PO.

  Purchasing

• Reviews PReq and Approves

• Reviews the PReq and ensures that the sole source questions are complete
• Upon receipt of the PReq and fully signed subaward, the Purchasing Agent (PA) reviews the Preq, checks contract details and approves the PReq.
• Assigns a Purchase Order (PO) number
  • *If over $25,000.00, the PReq is reviewed and approved by the Director of Purchasing.
• Loads the PReq into PSoft, makes final changes and approves the PO.  The PO dispatch processes run nightly and the following business day the PO is printed.
• Electronically sends the fully executed subaward and PO to subawardee or the original PO documents to DSP

Principal Investigator/Department 

• Background for Subrecipient Monitoring
  • OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) ("Uniform Guidance"), specifically 200.331, requires pass-through entities to evaluate each subrecipient's risk of noncompliance in order to determine the appropriate monitoring level, monitor the activities of subrecipient organizations to ensure that the subaward is in compliance with applicable Federal statutes and regulations and terms of the subaward, and verify that subrecipients are audited as required by Subpart F of the Uniform Guidance. The University of Iowa complies with the preceding federal requirements and applies this policy to all outgoing subawards under externally sponsored projects.
• PI communication with the Subrecipient
  Information contained in the subaward states the deliverables required, administrative requirements and applicable laws and regulations with which the subrecipient must comply. This agreement and the referenced prime award define the subrecipient relationship. The PI and any designees administering the subaward should be familiar with and understand the terms and conditions of the agreement.
  • Communication should continue throughout the collaboration through telephone calls, emails, letters and site visits, as necessary. Any potential conflict or issues regarding non-compliance should be immediately brought to the attention of DSP.
• Work with DSP to Modify the Subaward
  Any changes or modifications to the subrecipient agreement shall be approved and executed through DSP. This includes all PI/departmental and subrecipient requests for re-budgeting, foreign travel, equipment purchases, subrecipient PI changes, and the hiring of consultants.
• PI is Responsible to Review and Monitor Subrecipient's Technical Performance and Progress documenting their review*, and locally retaining (in the PI’s or departmental records) those subrecipient reports as part of the regular record retention schedule required for the prime award**.
  • Verify that the subrecipient's statement of work is performed timely and is in line with the proposed and funded statement of work (SOW).
  • Review the technical/performance reports.
  • Collect and retain invention reports.
  • Verify that the subrecipient's compliance requirements are up-to-date (e.g., approvals for human subjects or animal subjects).
  • Maintain regular contact with the subrecipient.
  • Communicate any deficiencies to the subrecipient promptly. Any potential conflict or issues regarding non-compliance should be immediately brought to the attention of DSP.

*e.g., an email back to the subrecipient indicating the report has been reviewed and is acceptable, or annotating on the report itself “Reviewed, Approved” with PIs’ signature and date. **Generally the record retention period for federally funded awards is three years after project completion.

• PI/Department Invoice and Payment Processing
  When approving invoice payments to subrecipients on cost reimbursable awards, the validity of expenses must be verified along with the achievement of scientific and technical progress by the PI or department designee. 

  • Verify the expenses are allowable, allocable, and reasonable pursuant to the approved budget and the terms of the subaward.
  • If milestone or deliverable based the subrecipient invoice clearly outlines which milestone or deliverable met with a coordinating cost.
  • Submit the signed and certified invoice via the UI Purchasing Receipting Process.
  • Monitor Workflow for comments from Purchasing or GAO.
  • Notify Accounts Payable (AP) with a copy to GAO immediately if an invoice payment should be placed on hold, please reference the Subaward or PO number.

  GAO

• Reviews Invoices
  • Verifies that required information has been included on the invoice.
  • Verifies total cumulative expenses do not exceed authorized budget.
  • Verifies invoice period is within subaward period of performance.
• Per the Uniform Guidance and the University of Iowa's Negotiated Indirect Cost Rate Agreement (NICRA), for MTDC based budgets, the UI can only recover the UI F&A rate on the first $25,000 of each subaward and then the remaining amount of that subaward goes to "Not subject to F&A line".
  • MTDC or Modified Total Direct Cost budgets should include $25,000 on IACT line 6230 "Subject to F&A" and the remainder on line 6231 "Not Subject to F&A".  The first $25,000 is cumulative over the course of the project meaning if the subaward is $12,000 in year one, $13,000 should still go to IACT 6230 in year two.
  • TDC or Total Direct Cost based budgets should include the full amount of the subaward on IACT line 6230 for all new and subsequent funding.  
• GAO receives invoice from UI department. GAO can then review for approval for payment and routes to AP for processing.
  • If final invoice, GAO may hold and review per the terms of the award prior to final approval.
• Reviews carryover requests for accuracy and prior approval in accordance with the prime award.

• Review the OGS request, verify all information needed to draft subaward is present (including compliance and sponsor approval)
• Determine the appropriate subaward template or draft the agreement, incorporating appropriate flow through provisions of the UI's prime award and terms required as applicable by the Uniform Guidance, 2 CFR 200, Federal Acquisition Regulation, FARs, and UI policy.  
• Sends draft subaward to GAO for risk assessment review of the subrecipient and for alignment between the project’s financial structure, sponsor requirements, and the appropriate subaward type.
• Sends the subaward agreement to the subrecipient via DocuSign for review and electronic signature. This triggers an automatic e-mail to the UI Contacts indicated on the request with a link to the project view in the DSP Research Tracker where the subaward draft is available.
• Negotiates general administrative terms with the subrecipient. Consults with the PI and department regarding questions on the scope of work and budget.
• DSP-contracts monitors monthly to follow up with the subrecipient if the signed agreement is not returned to DSP.
• Once agreement is fully signed, DSP will push the subaward PO to the AP-PO system to permit invoicing. Subsequent funding or extensions in time on a subaward PO must be initiated on DSP Research Tracker.