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Proposal Submission

A subaward may be needed if another organization is performing work on a sponsored program or project where Tufts is the prime award recipient. For example, a project where a Tufts Principal Investigator has received an NIH award, where some of the work of the project will be done by a colleague at Harvard. Subawards are needed if the collaborating organization will perform substantive programmatic work on the sponsored program or project. Both a tool and guidance are available to assist in determination of whether the relationship between Tufts and the collaborating organization should be classified as a subaward or a purchasing contract.

Additionally, Tufts often serves as a subawardee on sponsored projects managed by other entities.

Please note the following information for how best to set up a subaward. Scenario A an award to Tufts with a subreceipient, and Scenario B describes an award to another institution in which Tufts will receive a subaward.

A. When a Tufts Principal Investigator partners with another PI and institution to carry out a portion of a project awarded to Tufts, the following must be received from the collaborating institution and routed to the Office of Research Administration (ORA) along with the application package:

- A Budget that meets the sponsor’s requirements
- A Scope of Work describing the collaborating institution’s participation in the project
- A Statement of Intent signed by the subrecipient institution business official
- For Public Health Service (PHS) projects (which includes NIH awards), the subrecipient must certify that it is compliant with 42 CFR 50 Subpart F, Promoting Objectivity in Research. If the subrecipient certified their compliance in the Federal Demonstration Partnership Institutional Clearinghouse, it should be marked as compliant on the Internal Coordination Form. If the subrecipient is not listed in the clearinghouse, they must fill out a FCOI Disclosure (non-Tufts) Form. This form must be signed by the non-Tufts PI and their Authorized Institutional Official. Subrecipient organizations that do not have financial conflict of interest (FCOI) policy that is compliant with the PHS regulations are subject to Tufts Financial Conflict of Interest in Research policy.

Additional time will likely be required at the subrecipient institution for their internal review and sign-off before inclusion in Tufts proposal. Please plan for this additional time prior to the deadline for Tufts internal approvals.

B. When Tufts is the subrecipient, the routing and approvals at the time of proposal submission must follow the internal proposal process. Prior to submission of the package to the prime institution, the Internal Sponsored Coordination Form and the Financial Interest Disclosure Form must be sent to ORA (or routed via Research Administration System (RAS)). It is recommended that Tufts PI also prepare and sign a letter of support expressing their intent to collaborate with the colleague(s) at the prime institution. Upon review and approval of the budget, budget justification, scope of work, and any other pertinent information, ORA will issue the institutional statement of intent (or sign the statement of intent provided by the prime institution).

If either the subrecipient or the prime organization is a first-time collaborator with Tufts, the ORA Signing Official will request that this organization would be authorized in Research Administration System (RAS).

New Subaward and Subaward Amendments

ORA negotiates incoming subawards and issues subawards to collaborating organizations when Tufts proposals are funded. Subawards and subaward amendments are signed by ORA Signing Officials.

  • Prior to issuing a new subaward from Tufts, the Risk Assessment Questionnaire (RAQ) is completed by ORA and a copy is uploaded into the Research Administration System (RAS) award record. Input from PIs and Local Research Administrator (LRA) is sought when appropriate. The scores from the RAQ are used to assess risk of the specific subaward and to determine whether any additional award conditions need to be included in the subaward agreement.

  • Prior to issuing a subaward amendment, a copy of the Continued Assessment Tool (CAT) is completed by ORA and uploaded into the RAS award record. CAT is used to assess whether any changes are needed in the subaward terms and conditions and offers a mechanism for documenting actions taken and the reasoning behind them. Amendments that are issued in the middle of the budget year, including no cost extensions, do not require completion of the CAT as long as no considerations exist for reevaluation of the risk level of the subrecipient.

  • As part of completing the RAQ, ORA will request audit information from entities that are not subject to single audit (those are non-federal entities that expend less than $750,000 in Federal awards during their fiscal year). A copy of the information will be shared with SPA for recording in the subrecipient audit file.

  • Verification that the subrecipient and the Principal Investigator (PI) of the subrecipient have not been debarred or suspended from receiving federal funds is part of completion of RAQ and CAT.

  • For subrecipients deemed to require closer monitoring, Tufts may impose additional award conditions as needed. The award conditions may include the following requirements:

    • Submission of a brief technical report with each invoice to confirm acceptable performance.

    • Requests of supporting documentation prior to or subsequent to approving the invoice to enable additional project monitoring.

    • For subawards with advance payments, reconciliation of advanced amounts prior to issuing subsequent payments is required. Projected expenditures for the next payment period must include a list of expected purchases.

    • For subawards with animal and/or human subjects work, copies of IACUC and IRB approvals are requested before execution of the subaward for high risk subawards.

Note: Detailed budgets are always required for high-risk subawards.

When a subaward agreement is fully executed, it must be submitted in the electronic requisitioning system and routed to the Office of Sponsored Programs Accounting (SPA) for approval. Once all approvals are obtained, a purchase order is created in PeopleSoft. The account number(s) on the requisition/purchase order should correspond with the budget that was entered into the appropriate grant, using the range of accounts (5151-5164) set aside for subcontracts.

Helpful Hint: when an “Under $25K” and “Over $25K” accounts are used, the requisition should contain two ‘items’ rather than a split.  This will ensure that Accounts Payable uses the first $25,000 of the purchase order from the “Under $25K” to pay invoices, before using the funds in the “Over $25K” line.

Subrecipient Monitoring

Tufts University takes a risk-based approach to subrecipient monitoring, focusing monitoring efforts more frequently on those subrecipients who are deemed to pose a greater risk for potential non-compliance.

Principal Investigators (PIs) and Local Research Administrators (LRAs) use the following subrecipient monitoring procedures when appropriate:

  • PIs communicate regularly with subrecipient PIs and review progress/programmatic reports or other specified deliverables on a timely basis to ensure the subaward funds are being used for authorized purposes and that performance goals are being achieved. Any issues should be investigated, documented, and resolved by the PI. 
  • LRAs monitor receipt of progress/programmatic reports or other deliverables for timeliness.
  • PIs and/or LRAs perform an expense to budget comparison for cost-reimbursement subawards. The subrecipient’s invoices are generally required to show both current period and cumulative expenses.  
  • PIs and/or LRAs are responsible for reviewing and documenting the review of financial reports and invoices received from the subrecipient to ensure that they are in compliance with Federal statutes, regulations, and the terms and conditions of the subaward. By signing the invoice, the PI is confirming that the costs are reasonable, allowable, allocable, reflect the work performed and are in accordance with the terms of the subaward agreement. If the PI chooses to have a designate sign the invoices, the individual must have first-hand knowledge of the project in order to judge the quantity and quality of the work represented on the invoices. Once the PI or his/her designate signs, the invoice should be returned to the appropriate SPA Specialist. S/he approves the invoice and forwards it to Accounts Payable for payment under the assigned purchase order number. The Subrecipient Invoice Checklist should be used as a guide for reviewing subrecipient invoices.
  • PIs and/or LRAs are responsible for verifying that the subrecipient is adequately meeting any cost sharing commitments made under the terms of the subaward and that the subrecipient's indirect costs as charged are in compliance with the indirect cost rate specified in the subaward.
  • LRAs should request that the subrecipient provide clarification of invoiced charges that appear unusual, excessive, or otherwise questionable. LRAs may request detailed justification to verify the costs are allowable.
  • For subrecipients identified as requiring closer scrutiny, PIs and LRAs should work with ORA and SPA to establish additional channels of communication and monitoring methods.

PIs should communicate with ORA and SPA regarding any change in expectations of performance of work, payment terms, change in key personnel, reporting requirements, budgeting, deliverables, etc. If work stops or a change in the scope of work results, ORA and SPA should be notified and appropriate agreement changes implemented.

Sponsored Programs Accounting (SPA) uses the following subrecipient monitoring procedures contacting PIs or Local Research Administrators, when appropriate:

  • Invoices received from sub-recipients are required to include specific certification language that can be found under CFR 200 Subpart E 200.415 to assure that expenditures are proper and in accordance with the terms and conditions of the award and approved project budgets.
  • SPA is responsible for reviewing and signing invoices received from the subrecipient to ensure that they are in compliance with Federal statutes, regulations, and the terms and conditions of the subaward. The Subrecipient Invoice Checklist is used as a guide for reviewing invoices.
  • SPA verifies that subrecipients if applicable, are audited as required by the Audit Requirements in the Uniform Guidance and will review the subrecipients’ audit reports to assess audit findings, if any.
  • SPA will issue a management decision for audit findings that relate to awards Tufts makes to subrecipients. For single audit organizations a management decision must be issued within six months of acceptance of the audit report by the Federal Audit Clearinghouse.
  • SPA is responsible for following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies provided to the subrecipient directly related to Tufts prime awards detected through audits, on-site reviews, and other means.
  • For subrecipients not subject to Audit Requirements of the Uniform Guidance, audited financial statements and/or completion of a financial controls questionnaire will be requested.

ORA and SPA coordinate continued subrecipient risk assessment and subrecipeint monitoring to ensure a comprehensive, linked approach.  During annual assessments, ORA and SPA offices jointly analyze the subrecipient audit documentation and any relevant information from departments to ensure that the risk rating for each subrecipient is appropriate. ORA and SPA communicate determinations of risk to PIs and LRAs, along with any additional requirements and need for special monitoring. 

The subrecipient risk level (low, medium, or high) is recorded in the organization address book in RAS based on the institution risk level. ORA updates subrecipient risk level in RAS upon completion of each RAQ and/or CAT. Subrecipient risk level will also be updated during the continued risk assessment based on the review of the annual audit information.

ORA and SPA provide training and guidance in interpreting regulations and subrecipient award terms and conditions.