Grant, Contract & Gift Accounting Manual
Section 206: Subcontracts
- 206: Subcontracts
- 206-01: Subaward vs. Procurement
- 206-02: Managing Subawards
- 206-03: Property Purchased by Subrecipients
Oregon State University (OSU) annually receives over 200 million dollars in support of research and sponsored projects. Most of the funds come from federal agencies and OSU passes through a portion of the sponsored award to another entity for the purpose of completing programmatic effort on the project. The legal relationship is between the prime recipient (OSU) and the subrecipient. It is important to maintain this relationship to avoid conflicts of interest between the sponsor and subrecipient. All project administrative matters of the subaward must go through OSU. See Conflict of Interest Policy
Those entities consist of other universities, private companies and, occasionally, other federal agencies that will assist and/or collaborate with the OSU principal investigators on sponsored projects. The agreements with other entities are called subawards and are written by the Office of Sponsored Programs – Research Contracts. The terms and conditions of a sponsored award received by OSU in support of a project are incorporated into the subaward.
There is a series of account codes assigned for tracking of budget, revenue and expenditures for individual subawards. This series allows for tracking of up to fifteen different subawards per grant fund. The list of account codes and their descriptions can be found on the OUS Fiscal Policy Manual,
To determine whether a sponsored award is a procurement or subaward, see the Sponsored Programs website for guidelines.
Responsibility of PI, Business Center
- Notify the university Office of Sponsored Programs – Research Contracts when a subaward or amendment needs to be written.
- Provide an adequately prepared statement of work describing how the prime recipient (OSU) expects the subrecipient to accomplish the tasks.
- Review invoices, approve for payment and input into Banner. If the encumbrance number is not referenced when paying invoices on a subaward, Business Centers will need to make manual encumbrance corrections.
- Communicate with Key Personnel listed in subaward.
- Ensure all reporting obligations are met.
- Verify that the subaward scope of work has been completed.
To communicate with OPAA on any issues of non-compliance or if the Prime PI (OSU) is withholding payment for any reason.
Responsibility of Subrecipient
- Be aware of all contract terms and conditions; OMB Circulars A-110, A-21, and A-133 are the guides for flow down from a federal assistance award. Commercial sub-recipients also need to be aware of Federal Acquisition Regulations subpart 31.2 –Contracts with Commercial Organizations.
- Submit invoices with signed certification, detailed by budget line item, to the university no more frequently than monthly, but at least quarterly.
- If subrecipient has committed to cost share, subrecipient shall document the cost share for the period with each invoice.
- Maintain acceptable financial systems and accurate records that identify the award’s expenditures.
- Maintain effective control over and accountability for all funds, property, and other assets.
- Maintain consistency with applicable cost principles.
- Communicate with the Principal Investigator at Oregon State University.
- Ensure all reporting requirements are met.
- Submit final invoice and closeout documentation after award termination date or as otherwise noted in agreement.
- To comply with record and retention requirements.
- To provide backup documentation, when requested, for all costs.
Responsibility of the Office of Post Award Administration
- Set up subaward to create a file in Nolij.
- Encumber subcontract in Banner and verify budget dollars. Notify Business Center accounting staff and OPAA grant accountant, if any adjustments are necessary.
- Review invoices prior to sending to Business Center, and monitor subawards to ensure invoices are tied to general encumbrance, appropriate account codes were used for payment, equipment purchased only if allowed on subaward , monitor reporting of cost share, and verify correct indirect cost rate used.
- Send closeout letters to subrecipient prior to award termination date, and begin the closeout process.
Subawards are usually predicated on the prime award and a copy of the prime is typically attached to the subaward agreement. Typically the terms of the prime award flow down to the subrecipient. If there are unusual property requirements, they will be stated in a special conditions attachment to the subaward. These will include title restrictions and reporting requirements.
Any equipment purchased or constructed by a subrecipient with award funds must be approved in the budget. If property is federally owned, the subrecipient is required to comply with federal regulations (per A-110 or FAR 45.510, as appropriate) to adequately care for and maintain that property and assure that it is used only as authorized by the award. The subrecipient’s approved property control system must include procedures necessary for accomplishing this responsibility. Equipment reports must be submitted to OSU for referral to the sponsoring agency, as required by the prime award.