Subrecipient Agreements

Subaward was included in the funded proposal

If a subaward was included in the funded proposal, the department begins the process by submitting a Subaward Request for each subrecipient. Before submitting, confirm that the external organization is correctly classified as a subrecipient, not a vendor or consultant. Refer to the Subrecipient vs Vendor guidance as needed.

This page describes the Sponsored Programs Administration (SPA) process.

• The Center for Clinical Trials and Corporate Contracts (CCT) issues subawards under industry-sponsored clinical trials.
• Strategic Sourcing and Acquisition Services issues consultant and vendor agreements

Initiate the Subaward Request after UMB receives the award notice and the Award has been set up in Kuali Research. You will need the Kuali Research (KR) Award ID and other information to complete the Subaward Request.

After-the-fact Subawards

If the subaward was not included in the original proposal, the subrecipient must be listed as an Approved Subaward in the KR Award record before a Subaward Request can be submitted. Sponsor approval is usually required before UMB issues the subaward.

Whether prior approval is required depends on the award and sponsor:

• Most agreements and contracts require that UMB obtain the sponsor's prior approval before entering into any subaward. Review the agreement terms and conditions.
• For NIH grants only, sponsor approval is required for foreign subrecipients but not for domestic (U.S.) subrecipients.
• For all other sponsors, you must review the award terms and conditions and sponsor policies to determine whether sponsor approval is required.

If NO prior approval is needed, email SPA-Subcompliance@umaryland.edu with the KR Award number and the organization(s) to be added as an Approved Subaward.

If prior approval is required, work with your SPA Team to request approval. The request is initiated by the PI and signed by SPA. Written approval from the sponsor’s grant or contract officer is required before SPA updates the KR Award record.

Budget
Use the Budget template-subaward request. A budget is required for new subawards and for modifications that add dollars to the subaward. The budget will include salary, fringe benefits (at the subrecipient's rate), operating expenses (supplies, equipment, travel), and F&A costs.

For fixed price/deliverable subawards, provide a payment schedule including deliverables (and due dates) and payment dates and amounts.

Scope of Work
This document should describe, with a reasonable amount of detail, what the subrecipient investigators will do for the project.Statement of Work template 

Commitment form
The completed and signedSubrecipient Commitment Formmust be uploaded to the Subaward Request. (This form is not required at the proposal stage.)

Unique Entity ID (UEI) requirement
When the prime sponsor is federal, the subrecipient's Unique Entity ID (UEI) is required by award terms and is used for UMB's reporting to the federal government. Subrecipients obtain a UEI from Sam.gov.

Special conditions or requirements
To be included in the subaward may be described in the Subaward Request. Examples: additional reports, data, shared research materials, and timetables. Include these in the Comments section of the form.

When applicable, SPA will require:

• IRB or IACUC approvals.
• Human subject training certifications for all key personnel.
• Approval for use of select agents.
• Financial Conflict of Interest (FCOI) certifications for all key personnel (NIH-funded projects).
• Copy of the subrecipient's Federally Negotiated Indirect Cost Rate Agreement, when applicable, and if not provided in the proposal

1. The PI authorizes the subaward request, via workflow for the Subaward Request or via email for internally funded subawards.
2. New subawards undergo a risk assessment process, which may involve communications between SPA and the subrecipient. If the proposed subrecipient is a foreign organization, an export compliance review is performed.  Under certain circumstances, the Conflict of Interest office is notified.
3. The initiator/submitter of the Subaward Request can monitor the status of the workflow approvals:
4. Log into Kuali Build. Click on My Documents, and then select Submitted
   • If the Status column says "Complete", then the form has been approved. Submitters receive an email with a copy of the approved form. At this point, the Kuali Research record for this subaward has been created and the SPA Sub Team will send the subaward to the subrecipient.
   • If the Status column says "In Progress", then the form is still in the workflow. Click on the link in the Form column to view the form, then in the left column of the form, toggle from Review to Status. If the form is at the approval stop for "SPA Approval - Sub Team", look at the date of notification under "Submitter notified that SPA Sub Team is receiving form". This starts the 15-business-day turnaround time in SPA's business process for subaward review. After 15 business days, if you have not heard from the SPA Sub Team, send an email (including your KB form number) to SPA-Subteam@umaryland.edu
5. The subaward is sent to the subrecipient for signature and the department is notified.
6. The subaward is signed in SPA only when all approvals are in place.
7. The fully executed subaward is sent to the subrecipient and the department.
8. The department requests a purchase order via Quantum standard procedures.
9. The department informs the subrecipient and SPA of the purchase order number.

1. SPA informs the subrecipient of the purchase order number
2. The subrecipient submits an invoice, referencing the assigned purchase order number
3. Invoices are processed by Accounts Payable
4. Review each invoice to confirm that the subrecipient has performed the work and that the charges are reasonable, allowable, and within budget. Subrecipient Monitoring Invoice Checklist
5. PI must review and approve in writing all expenditures for work completed during the period stated on any invoice received.
   As an example, the PI could confirm via email to the department administrator that the subrecipient has made progress in the project work, completed milestones (describe), or submitted data and/or reports, and that the expenditures are approved as invoiced.
6. When funding is a federal grant or cooperative agreement, use the UMB RPPR Subrecipient Progress Report Form to collect information from the subrecipient for use in preparing required RPPR submissions.

Tips

• Monitor your subrecipient to ensure that they are invoicing regularly and on time.
• Monitor your subrecipient to ensure that progress is being made. Document the progress and completion of project work: keep records of telephone calls, meetings, emails, reports, deliverables, and compliance requirements (such as IRB approvals).
• As part of the invoice review, compare the effort reported by key persons with the approved (awarded) effort to ensure that the effort commitment is met. The effort should be reasonable for the progress made. If there is a "disconnect", follow up with your subrecipient contacts to work through the issue.
• If the subrecipient is not performing or has not submitted the required reports, notify Accounts Payable to delay future payments until the issue is resolved. Document the issue and related communications. Keep the SPA Subawards Team apprised of the issue and resolution.

1. Department requests changes to the subaward using the Subaward Request. Possible changes include:
   • Add continuation year funding (increase and extend)
   • Increase or reduce the subrecipient’s budget
   • Change of Subrecipient PI
   • Carryover of funds from one project year to the nextEarly
   • termination of the subawardChange of
   • subrecipient (e.g., due to transfer of subrecipient PI)Exten
   • sion of agreement (The term of the subaward cannot be extended beyond that of UMB's award.)
2. Approved changes will be incorporated in a modification to the subaward issued by SPA.
3. Some changes require sponsor approval. When required, sponsor approval must be obtained before the subaward can be modified. Requests for sponsor approval are initiated by the PI and signed off by the SPA authorized official.
4. Requests from the subrecipient regarding changes to the agreement will be forwarded to the UMB PI for review and approval.
5. In the Subaward Request
   • Identify the change(s) to be made - see instructions
   • Include updated approvals (human subjects, animals) and certifications when applicable
   • Upload a budget for any increase to the subrecipient's current awarded budget
   • When applicable, provide an updated scope of work and/or reporting requirements
     
     The Subaward Request will be verified and authorized by the PI.
6. Changes to the purchase order:
   • The department must process approved changes to the purchase order when required.

A subaward should be closed out at the end of the project after all technical reports or other deliverables have been completed by the subrecipient, and after the subrecipient's final invoice has been paid. The steps to close out a subaward should also be taken if a subaward is terminated early, before the end date in a signed agreement.

Subaward Request - Early Termination

For closeout, the following items are needed:

• Within 30-45 days after the end of the budget period, the subrecipient must submit an invoice marked as "Final". The PI should approve this final invoice for payment only if all the required reports and deliverables have been received from the subrecipient.
• The department administrator should ensure that payment of the final invoice expense has been posted. Contact Strategic Sourcing and Acquisition Services to have any remaining balance of the subrecipient purchase order disencumbered.
• The final invention report to the sponsor must include any inventions first conceived or first reduced to practice by the subrecipient personnel under the subaward.
• If UMB and the subrecipient entered into any material transfer agreement (MTA) related to the subaward, review the MTA to determine if the exchange of materials is still needed or should be ended. Contact the Center for Clinical Trials and Corporate Contracts for assistance.
• SPA will request any other documents that may be required from the department or the subrecipient for closeout.