Issuing and Managing Outgoing Subagreements

The first step in the subcontracting process is completion of the Subcontract/Subaward Request Form in coordination with your Department’s Financial Officer. The form and any necessary backup materials are then forwarded to the Office of Research Affairs (“ORA”), which will prepare and issue the subcontract/subaward (subagreement). If Subrecipient’s total budget, or the cumulative total of all Subrecipients, equals 50% or more of Prime Award total amount, prior ORA approval is required and would be obtained by contacting subawards@pennstatehealth.psu.edu

The form and any necessary backup materials are sent to the Office of Research Affairs (ORA), which will prepare and issue the subcontract/subaward (subagreement).

Prior to issuing the subagreement, ORA will perform a risk assessment in order to determine the subrecipient’s capacity to properly manage the funds (i.e., review a copy of an independently audited financial statement or Single Audit Report).

Upon full execution, it is the department’s and principal investigator’s responsibility to manage the subagreement. The principal investigator (PI) is responsible for monitoring the subrecipient’s progress and approval of invoices to ensure the costs are appropriate and commensurate with the work performed. The PI is responsible for signing the Technical Release Form accepting final deliverable and technical performance.

Following completion of the subagreement, ORA is responsible for the final review and analysis of costs incurred against the subagreement and for obtaining all required closeout documents.

The Office of Research Affairs:

• Performs risk assessment prior to issuing subawards, including financial audit reviews. That information can be found in the following ways:
  • Check the FDP FCOI Clearinghouse or FDP Expanded Clearinghouse; if the institution is on the expanded clearinghouse list, the information from that site can be used to complete the risk assessment and gain pertinent information. ORA should print out the summary of the profile, complete the RAQ for a new agreement or a CAT for an amendment; and complete the Risk Assessment Determination Form. ORA staff should do the following
  • Look up the latest Single Audit for the institution here.
  • Check for delinquent debt in SAM.gov.
  • Check USASpending.gov.
  • Print out any and all relevant materials being used to complete the risk assessment and upload the documents to the Risk Assessment Negotiation Log. Once completed, send the log to the contract file.
• Reviews contractual obligations.
• Issues a subaward document and negotiates terms and conditions, if necessary.
• Reviews documentation submitted by the department to verify subrecipient monitoring.

The department:

• Fills out the online Subaward/Subcontract Request Form and provides any special reporting/invoicing instructions (if applicable), F&A rate agreement, subrecipient budget and subrecipient scope of work.
• Ensures compliance with all restrictions and obligations associated with the subaward.
• Approves invoices for payment after ensuring all costs are allowable, allocable and reasonable (incurred within the period of performance) and are aligned with technical progress.
• Obtains the final invoice prior to closeout.
• Ensures that the Certification of Technical Completion has been completed by the PI prior to closeout.
• Forwards a copy of the final cumulative invoice and completed Certification of Technical Completion to ORA.

The principal investigator:

• Provides oversight during the subaward period of performance.
• Approves invoices for payment.</li<>
• Ensures full and timely compliance with all restrictions and obligations of Prime Award.
• Monitors scientific progress and subrecipient’s adherence to terms of subaward.
• Follows up on late or missing reports/deliverables.

Checklists for incoming and outgoing subaward management are available via Box (Penn State Access ID login required).