ºù«ÍÞÊÓƵ

°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 OCGSubcontracts@colorado.edu.

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

The Principal Investigator (PI) is ultimately responsible for the subrecipient. The DRA and OCG Subcontracts Team may provide support and guidance, but the PI must accept responsibility for all subrecipients.Ìý

The Subagreement Vendor or Consultant Treeis available to help departments and PIs decide what sort of relationship CU ºù«ÍÞÊÓƵ will have with the collaborator. If you still have questions, contact your Proposal Analyst.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.

• Subrecipient Commitment Form or Subrecipient Statement of Collaborative Intent (for use only with FDP Universities) Ìý
• Subrecipient detailed budget in a format appropriate for the Prime Sponsor Ìý
• Subrecipient Budget Justification Ìý
• Subrecipient Statement of Work (SOW)
  • This should include a clear description of the work to be performed, proposed timelines, and deliverables. The SOW should be detailed to ensure expectations are clear and can be enforced if there is any future disagreement between CU and the Sub. Ìý
• Subrecipient’s Federally Negotiated Indirect Cost Rate AgreementÌý
  • Not required if the subrecipient is only collecting the de minimis rate or if the indirect rate is restricted by the prime sponsor.Ìý
• Any other documentation required by the Prime Sponsor (for example, Current and Pending, Biosketch, Collaborators and Other Affiliations, Facilities, Equipment and Other Resources, etc.). Your Proposal Analyst will help you to determine if additional files are required. Ìý

Additional documentation will be required to issue a subagreement if the Award is received. For that list see FAQ below "what documents are required to process a subaward at the time of award?" ÌýÌý

The Subrecipient Commitment Form is a method for CU ºù«ÍÞÊÓƵ to gather compliance information from the Subrecipient. The form: Ìý

• Shall be signed by the authorized official of the subrecipient institution committing the subrecipient to the proposed work.Ìý
• Provides a checklist of documents and certifications required by sponsors and CU ºù«ÍÞÊÓƵ.
• Serves as Representations and Certifications for the subrecipient institution. Ìý
• Requires the subrecipient to certify that the appropriate programmatic and administrative personnel involved are aware of relevant sponsor policies and are prepared to establish a subagreement consistent with those policies. Ìý

Once an incoming grant or contract (i.e., the prime award) is fully executed by OCG, it is routed to the Campus Controllers Office (CCO) for project setup. Once they have finished it is routed to the Subcontracts team. Only then can they begin work. The Subcontracts Team cannot begin work on an outgoing subagreement until the prime award has been fully set up.ÌýÌý

Some of these documents should have already been provided at the proposal stage.Ìý

Completed/provided by Subrecipient:

• Subrecipient Commitment Form or Subrecipient Statement of Collaborative Intent (only used with FDP Universities) Ìý
• Subrecipient Budget Ìý
• Subrecipient Budget Justification Ìý
• Subrecipient Statement of Work (SOW) Ìý
  • This should include a clear description of the work to be performed, proposed timelines, and deliverables. The SOW should be detailed to ensure expectations are clear and can be enforced if there is any future disagreement between CU and the Sub. Ìý
• Subrecipient’s Federally Negotiated Indirect Cost Rate Agreement Ìý
  • Not required if subrecipient is only collecting the de minimis rate or if the indirect cost rate is restricted by prime sponsor. Ìý
• Subrecipient’s most recent Single Audit or their No Audit QuestionnaireÌýÌý
• China Assurance (if this is under a NASA award) Ìý
• Human and/or animal subjects protocol approvals from the sub’s IRB or IACUC, if applicable ÌýÌý

Revised Budget, Budget Justification, and Statement of Work (if affected) will be needed if the subrecipient’s funding changes from proposal to award stage.

Completed by CU PI and/or DRA:

• Subrecipient Review FormÌý
  • This form should include any special terms that the PI would like incorporated into the subagreement (reports, communication, deliverables, etc.) or information the subcontract officer should be aware of when drafting the subagreement. Ìý
  • The prime award should be reviewed prior to completing this form to include any appropriate flowdown reporting requirements. Ìý
  • Export Control information if applicable .Ìý
• (required only for subcontracts) â¶Ä¯Ìý

Below is a general list of the Roles and Responsibilities of the Principal Investigator and Department. For more information please review the Subrecipient Monitoring page.

Principal Investigator

• Correctly identify Vendor vs. Subrecipient at proposal stageÌý
• Review past performance to assess the risk level of potential subrecipient during proposal stage
  • Submit a request to OCG for a preliminary review of the subrecipient organization at the proposal stage, if necessary
  • If there are any concerns, it is important that it is addressed at proposal stage
• Review and confirm the subrecipient's statement of work and budget are adequate and reasonableÌý
• Complete the Subrecipient Review form certifying responsibility for the subrecipient
  • Review the prime award for any non-standard terms and conditions to be included in the subagreement. This can include specifics regarding:
    • DeliverablesÌý
    • Reporting guidelines
    • Special invoicing requirements
• Monitor programmatic progress and the ability of the subrecipient to meet objectives of the subagreement and research project.Ìý
  • Review technical and progress reports and deliverables
  • Verify technical performance to invoices
• Review and provide written approval of subrecipient invoices
  • Monitor subrecipient's burn rate
• Provide written confirmation for each subagreement modification to OCG via the SPO markup.Ìý
• Provide consistent and thorough monitoring and review of subrecipient's technical performance
• Monitor each subrecipient throughout the period of performance and escalate compliance concerns to OCG if necessary

Department

• Assist the CU ºù«ÍÞÊÓƵ PI with the above subrecipient monitoring responsibilities
• Route the Subrecipient Review form to the PI when a new subrecipient is being set up under an award. Review form for completeness.Ìý
• Review invoices prior to sending to PI for approval and approving in CU Marketplace
  • Utilize the Invoice Monitoring/Approval ChecklistÌý
• Complete the SPO markup or route the form to the PI when the funding or period of performance needs to be changed on a subagreement and Blanket Purchase Order (BPO)
• Facilitate frequent communication between the PI, the project fiscal manager or project manager, and OCG's Subcontract Officer to promote early detection of any potential issues

The Subrecipient Review Form is an aspect of subrecipient monitoring.Ìý

This form should be completed by CU ºù«ÍÞÊÓƵ’s Principal Investigator (PI), who is ultimately responsible for the subrecipient. The PI should reference the prime award reporting requirements and terms when completing this form.

The form: Ìý

• Certifies that the PI has reviewed the sub’s statement of work and budget and determined that they are adequate and reasonable. Ìý
• Allows the PI to indicate what reports are required from the subrecipient.
• Allows the PI to indicate additional terms to include in the subagreement. Ìý

The (SSJ) is required for any subcontract under a sponsored project that is a contract. These subcontracts are considered a procurement, and federal regulations require all procurements go to a competitive bid process for collaborators. Ìý

However, the research conducted at CU ºù«ÍÞÊÓƵ is specialized and PIs often choose collaborators based on their unique capabilities. The SSJ documents why a specific subrecipient is the only source that can complete the research requested. This justification allows CU ºù«ÍÞÊÓƵ to move forward with the procurement (i.e., subcontract) without going to bid. Ìý Ìý

CU ºù«ÍÞÊÓƵ is subject to annual audit of our purchasing system, which includes a review of subcontracts. The SSJ is essential because it demonstrates CU ºù«ÍÞÊÓƵ's compliance with federal regulations that govern how government and taxpayer funds are expended.Ìý

The subagreement Blanket Purchase Order (BPO) is a payment mechanism for the subagreement. The BPO can only be modified after the subagreement has been formally modified by the Subcontracts Team. â¶Ä¯Ìý

If you are adding funds and it is incremental funding following the existing subagreement budget;

• Submit the , authorized by DRA or PIÌý

If you are adding funds (or reducing funding) that does not follow the existing subagreement budget:

• Submit the , authorized by the PI
• SendÌýa revised budget, budget justification, and statement of workÌý(if affected by the funding change)Ìýto ocgsubcontracts@colorado.edu.Ìý

If you are extending the end date:Ìý

• Submit the , authorized by DRA or PIÌý
  • The subrecipient's end date cannot exceed the prime award's end date.
  • If a No Cost Extension request form was submitted that included the subs’ information, a SPO markup may not need to be completed. Your Subcontract Officer will reach out if one is needed.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 Subrecipient
• Change in Principal InvestigatorÌýof Subcontractor (if they are named as Key Personnel in the Award)

Adding a new subagreement that was not on the original proposal will need approval from the sponsor. Contact your Grant or Contract Officer to begin this process. Depending on the sponsor, there may be specific documentation your Contract or Grant Officer may need to submit the request. â¶Ä¯Ìý

The Subrecipient and Participant Support Reallocation form will need to be completed once sponsor approval is received.

After the sponsor approval has been received and the Subrecipient and Participant Support Reallocation form has been processed through OCG and CCO, your Subcontract Officer will be able to assist with issuing the subagreement.ÌýÌý

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 Grant Officer or Contract Officer will work with the unit if any additional information is required before they take the necessary actions to initiate the change.