Subawards

Outgoing Subaward Tracker
See updates on the status of your outgoing subaward setup with the Outgoing Subaward Tracker.
Many applications submitted to federal agencies rely on collaborations with investigators from outside organizations. An agreement to collaborate, also known as a subaward agreement, must be established at the time of proposal submission.
Subawards are complex, legal documents that require careful consideration during proposal development, award setup, and award closeout. Learn more below, or reach out to your Sponsored Programs Officer with any questions.
- WEBAdministration and Monitoring of Subrecipient Agreements Issued to Third Parties Updated April 14, 2022
Subaward Basics
Definitions
Subaward
An award provided by a passthrough entity (such as BU) to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass-through entity.
Pass-Through Entity (PTE)
A non-Federal entity (such as BU) that provides a subaward to a subrecipient to carry out part of a Federal program.
Subrecipient
A non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program.
Subaward vs. Vendor Contract
Treating an entity as a either a subrecipient or a contractor is determined at the pre-award stage. A subaward is for the purpose of carrying out a portion of a Federal award and creates a Federal assistance relationship with the subrecipient, whereas a vendor contract is for the purpose of obtaining goods and services for the passthrough entity (BU)’s own use and creates a procurement relationship with the contractor. Learn more.
Challenges to Anticipate
Documentation requirements
Subaward actions can’t be processed until the subaward team has all proper proposal/budget documentation:
- Budget
- Budget Justification
- Scope of Work
- Letter of Intent (LOI)
Please send these to your Pre-Award Officer.
Common challenges: Obtaining documents from subrecipient, obtaining budgets throughout the life of the award when there are changes.
Adherence to deadlines
Sending and receiving subawards adds additional approval cycles to submission timelines: a delay in one institution will delay all institutions.
Hierarchy of review
Each subaward site is beholden to their internal institutional review process. Appropriate advance notification is crucial for successful collaboration.
Subaward Process
Step 1: Making initial decisions about subawards for a proposal
If BU is determined to be the submitting institution (receives at least 51% of direct costs), the PI will submit a formal request for a subaward. The PI is responsible for collecting all subaward documentation from all subrecipients and reviewing the documentation for appropriateness and approval.
Collection and review of the following documentation is required:
- Project info: Funding announcement, project title, subaward project period
- Budget: Direct costs/year, effort requirement, project-specific expenses
- Documents: Letter of intent, scope of work, budget & justification, biosketches, facilities and resources, letter of support, any funding announcement-specific requirements (e.g., IP letter)
- Application info: Performance site location, key personnel information, human subjects/vertebrate animals/select agents (if applicable)
Step 2: Creating and completing the subaward agreement
All actions related to subawards are triaged by Sponsored Programs Pre-Award on a first-in, first-out basis. In 2020, a small subaward team of four within SP managed 963 subawards and facilitated 80 actions per month.
- BU proposal submitted with all required subaward documentation
- Award received by Sponsored Programs and set up in Kuali/SAP (the amount budgeted at this stage for a subaward directly ties to the max amount we can obligate to a subrecipient without another account update)
- Subaward action kicked off by set-up team, routed to Subaward Officer
- Subaward Officer actions
- Locates subaward proposal documents
- Obtains PI concurrence for subaward action
- Performs subrecipient risk analysis (for new and some current subrecipients)
- Obtains funds commitment from SP Post-Award
- Creates subaward/modification
- Sends subaward/modification to subrecipient
- Subrecipient reviews, negotiates, signs, and return to subaward team
- Executed subaward uploaded into Kuali, distributed to BU PI, Department Administrator
- FFATA report submitted if required
The first point of contact for subaward questions should be your usual Pre-Award Officer, who will answer your question or direct you to the correct person.
Step 3: Invoicing and monitoring the subrecipient
- Subrecipient invoices sent directly to Sponsored Programs (subinv@bu.edu). Receive an invoice directly from a subrecipient? Send it to Craig Gerome (cgerome@bu.edu).
- SP-Post emails invoice to PI, DA, and SP Post-Award Officer
- PI completes initial review of invoice, raises any issues with DA and SP Post-Award Officer
- Sufficient technical progress has been made to justify payment
- A brief review of the invoice, with special attention to salary and wage costs invoiced
- A review of travel expenses to verify need for the travel during the billing period
- A review of material and supply charges for reasonableness
- Department Administrator checks invoice for:
- Dates: Within project period, no overlap with previous invoice
- Sufficient funds: To cover amount of invoice
- Cumulative amount: Matches total of new invoice plus previous amount billed
- Signed certification
- PI must approve the invoice: Signature on invoice or via email
- DA completes and submits the online Subrecipient Invoice Disbursement Form with invoice & PI approval
- SP Post-Award Officer receives form, invoice, and PI approval via Workflow. Once approved, it’s routed to Accounts Payable for final processing.
Key Takeaways
- Reach out to your SP Pre-Award Officer with any sub-agreement questions.
- Reach out to your SP Post-Award Officer to confirm final balance with sub-recipient.
- Don’t worry – if your set-up budget contained subaward funds, the action has been kicked off.
- Subaward actions go on hold until the sub team has all proper proposal/budget documentation, so send those documents to your SP Pre-Award Officer ASAP if they weren’t part of the original proposal.
- We need a corresponding budget for every subaward action that includes not-originally-proposed funding, even if it’s just a $100 supplement.
- All carryforward approvals need a corresponding budget.
- Expect your sub to be executed about 60 business days after you get an AN.
- Department should ensure invoices are sent directly to subinv@bu.edu