Outgoing Subawards FAQs

General

°Õ³ó±ðÌýUnit DirectoryÌýon ourÌýwebsite allows you to search by department to find your contacts at OCG. In the directory you willÌýfind your Proposal Analyst,ÌýGrant Officer, Contract Officer and SubcontractÌýOfficer.

The Subcontracts Team can also be reached through email at OCGSubs@colorado.edu.

2 CFR 200 Uniform Guidance provides guidance in as to allowable subrecipient indirect cost (F&A) rates, which include:

  1. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government; or
  2. In the absence of a Federally negotiated indirect cost rate agreement, a negotiated indirect cost rate between the pass-through entity and the subrecipient, which can be based on a prior negotiated rate between a different pass-through entity (PTE) and the same subrecipient; or
  3. The de minimis indirect cost rate (10% MTDC per §200.414(f)).

While the 2 CFR 200 allows for these three options, the ºù«ÍÞÊÓƵ does not negotiate rate agreements with subrecipients (option 2 above not allowed) and will accept either approved and current (option 1 above, final, predetermined, or provisional and not expired) Federally negotiated rate agreements or the de minimis indirect cost rate (option 3 above, 10% MTDC).

In some cases, subawards can be funded with cost share funds. The funds must be cash cost share and reviewed by OCG before approving funding subawards with cost share funds.

Outgoing Subs Proposal Stage Questions

Completed/Provided by Subcontractor but collected by either Proposal Analyst or Department:

Completed by CU PI/DRA:

Adding a subaward that was not on the original proposalÌýwill need approval from the sponsor. YourÌýGrant or Contract Officer can assist with beginning this process. Please use the reallocation form and process found at /ocg/manage-awards/outgoing-subawards/subaward-and-participant-support-reallocation.

Your Subcontract or Subaward Officer will be able to assist if/when Prime Sponsor approval is granted and the sub has been added to InfoEd.

Documentation needed to issue a Subagreement:

ÌýCompleted/Provided by Subcontractor:

Completed by CU PI/DRA:

It provides a checklist of documents and certifications required by sponsors. This form shall be signed by the authorized official at the institution which is the Sub'sÌýauthorized official committing to the proposed work. It also requires the Subrecipient to certify that the appropriate programmatic and administrative personnel involved in this application are aware of agency policy in regards to subawards and are prepared to establish the necessary inter-institutional agreements consistent with those policies.. It is also a method for CUÌýºù«ÍÞÊÓƵ to gather compliance information from the Sub.ÌýThis form also serves as a Representations and Certifications.

Every year CU is subject to audit for our purchasing system. A large part of that audit has to do with Subcontracts. We are using government andÌýtax payer funds so there areÌýmany rules and regulations that we must abide by.

The research that CU does is specialized. Our Principal Investigators (PIs) oftentimes have collaborators in their specialized field that they work with to do research. This is not the type of work that we could go to bid for, but we are expected to do just that.

OurÌýother option is a sole source justification. This works wellÌýfor us in that we usually only have one source that can do the work we needÌýdue to the years of study, work, and specialization of our PIs. If we failed this audit, we would have to have written permission from the Office of Naval Research for every Sub and SubÌýmodificationÌýbefore we could enter or modify a subcontract. This would take a large amount of timeÌýand delay our research projects.

Using the sole source helps us pass this audit because it explains why we did not go to bid to select our subcontractors.Ìý

OCG will work closely with the department to gather all information of the activity being performed by the outside entity. If it is not clear which category the entity falls into, OCG has the experience, knowledge base and authority to make the final decision.

Outgoing Subs Post Award Questions

Once a grant or contract is in place, it is routed to the Campus Controllers Office for project setup. Once they have finished it is routed to the SubAward/Subcontract team. Only then can they begin work. OCG cannot begin work on a Sub until the Prime Award is in place.

ÌýCompleted/Provided by Subcontractor:

Completed by CU PI/DRA:

The Sub Review Form is an aspect of subrecipient monitoring. It is used to show that the CU Principal Investigator (PI), who is ultimately responsible for the subcontract, has looked at the statement of work and the budget, and determined that the budget is adequate and reasonable to complete the work described in the statement of work.

It is filled out at the time of award to save the PI's timeÌýbecause oftentimes the budget that we propose and the budget that is awarded are different.

It is important to understand that the subcontract purchase order is a payment mechanism for the subcontract and can only be modified after the actual subcontract agreement has been modified.Ìý

If you are adding funds to a subcontract and it is incremental funding on an existing subcontract budget you only need to submit the .Ìý

If you are adding funds not previously expected, then you will need to submit the and sendÌýa budget and Statement of WorkÌý(if it is different from the original)Ìýto ocgsubcontracts@colorado.edu.Ìý

This is for the SubcontractsÌýTeam to gain department approval for each modification.Ìý

The complete answerÌýdepends on the terms of the award document.

In most cases, the following require Sponsor approval:ÌýÌýÌýÌý

  • Change in Statement of Work
  • Change in budget larger than 10%
  • Change in Subcontractor
  • Change in Principal InvestigatorÌýof Subcontractor (if they are named as Key Personnel in the Award)

Below is a general list of the Roles and Responsibilites of the Principal Investigator and Department. For more information please utilize the Subrecipient Monitoring Guide.

Principal Investigator

• Correctly identify Vendor vs. Sub

• Review past performance to assess the risk level of potential subrecipient organizations at the time of proposal

• Submit a request to OCG for a preliminary review of the subrecipient organization at the proposal stage, if necessary

ÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌýÌý If there are any concerns, it is important that it is addressed at proposal stage

• Confirm the statement of work and review any non-standard terms and conditions of the subagreement during the sub-agreement negotiation process

• Monitor programmatic progress and ability of the subrecipient to meet objectives of the subagreement

• Review and obtain written approval of subrecipient invoices by PI or designee

• Monitor each subrecipient throughout the period of performance and escalate concerns to OCG if necessary

• Review the sub-agreements reports

• Provide written confirmation of the review of each sub-agreement modification to OCG via a marked up SPO

• Provide consistent and thorough monitoring and review of subrecipient’s technical performance

• Verify technical performance to invoices

• Accept responsibility for all subrecipients

  • Complete the Sub Review Form noting any potential issues and certifying responsibility for the subrecipient

Department

• Monitor all activity and support PI

• Review Invoices prior to sending to PI for approval and approving in Marketplace

• Utilize the Invoice Monitoring/Approval Checklist

All carryforward actions impacting a Subawardee, effective 02/12/2024, requires the use of the Carryforward Restricted Project Allocation form.ÌýThe completed form must be signed by the Principal Investigator and Fiscal Manager and provided to that unit’s Grant or Contract Officer (GO/CO).

The GO/CO will work with the unit if any additional information is required before the GO/CO takes the necessary actions to initiate the change.

Outgoing Subs Closeout Questions

The Subcontracts Team handles the closeout of all subagreements.