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Sub-Award

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Sub-contract or Sub-award?

By definition a sub-recipient conducts project activities that are a primary purpose of the research program which are not conducted at the University. These activities should constitute a significant portion of the research program and require the leadership and direction of a responsible investigator located at the work site of the cooperating institution.

Need help in determining if it is a sub-award or sub-contract? Complete Determination of Sub-award v. Sub-contact (DOCX) and forward to Cindy.Jarvis@mail.wvu.edu along with a statement of activities that will be outsourced.

Any activity not meeting the definition of a sub-award should be handled via a sub-contract/service agreement. Information regarding service agreements is available on the WVU Procurement web site.

Initiate/Modify a Sub-award

A request to initiate a sub-award should be processed when a sub-award has been formally approved by a sponsor, either as part of a formal award action or after an award with the prior written approval of the award sponsor.

Sub-award Monitoring

Throughout the subcontracting process sub-recipient monitoring must take place. A copy of the OSP Sub-recipient Monitoring Policy (PDF) is available.

Definitions

Administrative Support Person (ASP)

The WVU/WVURC employee most directly responsible for assisting PI/PDs in the administrative management of an award. (e.g. processing invoices, award account management, account reconciliations, etc. This person can be a departmental accounting assistant, an EBO, or any other person charged with assisting a PI/PD in managing the non-technical portion of an award.)

Role:

• Review of invoices and comparison of invoices to established sub-award budgets;
Work with sub-recipient to clarify any charges which appear to be unallowable, un-allocable, unusual, or excessive;

• Advise PI/PD of invoice issues;

• Prepare and attach Sub-recipient Invoice Certification form to all sub-recipient requests for payment; and

• After PI/PD has certified the acceptability of the invoiced charges through the Sub-recipient Invoice Certification, process sub-recipient invoices in accordance with the sub-recipient invoicing process.

Contract

A legal instrument through which an external sponsor purchases research services, training services, and other services from WVU/WVURC. [For the purpose of this policy, contract does not include Personal Service Agreements and purchase orders used to procure supplies, consultant services, and equipment.]

Cost/Compliance Accounting Unit within Financial Services

• Conduct annual sub-recipient monitoring as provided for in this policy and elsewhere; and

• Determine in conjunction with OSP and SRA the type of monitoring required for sub-recipients not subject to OMB Uniform Guidance.

Letter of Intent

A document expressing the willingness of parties to participate in a project, usually provided prior to a sub-award agreement.

Office of Sponsored Programs (OSP)

• Initiate, negotiate, issue, amend, and sign sub-awards on behalf of WVU/WVURC;

• Coordinate the management of sub-awards on behalf of WVU/WVURC and advise others regarding the fulfillment of their sub-award management responsibilities;

• Advise the Associate Vice President for Research of all sub-award issues or deficiencies that present a compliance risk to WVU, WVURC or a risk to their respective reputations and continuing ability to receive external support;

• Ensure each sub-recipient proposal has the approval of the WVU/WVURC PI/PD and appropriate school/center officials;

• Evaluate sub-recipients and those directly responsible for the performance of services under sub-recipient agreements to ensure that they are not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded by any State or Federal department or agency;

• Obtain and verify F&A and fringe benefit rates for sub-recipients;
Verify that proposal and award budget information is correct and comprised of allowable costs;

• Verify that sub-recipient proposals and sub-award documents have the proper approvals by authorized officials at the sub-recipient’s organization; and

• Advise the appropriate University conflicts committee of any apparent conflicts of interest.

OSP Project Number

The unique number assigned to each project by OSP.

Principal Investigator/Program Director (PI/PD)

An individual designated by the recipient/sub-recipient to direct a project or program being supported by an award. He or she is responsible and accountable to recipient/sub-recipient organization officials for the proper conduct of the project or program. The recipient organization is, in turn, legally responsible and accountable to the sponsor for the performance and financial aspects of the award-supported activity.

Role:

• Obtain an approved proposal from proposed sub-recipients for incorporation into the proposal submitted to sponsors;

• Review of sub-recipient technical performance reports;

• Maintain communications with the sub-recipient PI/PD and technical team sufficient to assess the quantity and quality of work being performed;

• Receive, review and approve sub-recipient invoices (in coordination with ASP)
Certify that invoiced amounts are consistent with the amount and type of work performed to date;

• Pursue clarification of expenses that appear inappropriate (in coordination with ASP);
Notify OSP of changes that need to be made to the scope-of-work, budget, or period of performance;

• Notify OSP of sub-recipient’s failure to provide timely technical reports, invoices, or other requested information; and

• Advise sub-recipients that do not have a negotiated F&A rate of the allowability of charging a de minimis rate of 10%.

Procurement/Contracting/Payment Service

Review, approve and process sub-recipient invoices upon receipt and proper authorization from the PI/PD/ASP.

School/College/Center/Institute

• Provide oversight to PI/PD and ASP to ensure compliance with sub-recipient monitoring requirements; and

• Review and approval of sub-recipient payment requests.

Sub-Recipient

The party that receives a sub-award to perform substantive programmatic work under an award made to a recipient (does not include an individual that is a beneficiary of such program.)

Role:

• Perform the work set forth in the sub-award scope-of-work in accordance with the sub-award terms and conditions;

• Notify PI/PD and OSP of all issues and concerns related to sub-recipient’s performance and compliance;

• Comply with all requests for information related to the performance of the sub-award; and
Maintain a system of records related to the performance of project work in sufficient detail to permit WVU/WVURC and sponsor to evaluate sub-recipient’s technical and financial performance under the sub-award.

Sponsored Research Accounting (SRA)

• Perform the work set forth in the sub-award scope-of-work in accordance with the sub-award terms and conditions;

• Notify PI/PD and OSP of all issues and concerns related to sub-recipient’s performance and compliance;

• Comply with all requests for information related to the performance of the sub-award; and

• Maintain a system of records related to the performance of project work in sufficient detail to permit WVU/WVURC and sponsor to evaluate sub-recipient’s technical and financial performance under the sub-award.

Sponsor

Any entity providing financial or other tangible support for the research, training, and other mission activities of West Virginia University, directly, or through the West Virginia University Research Corporation.

Sub-Award

An award provided by a recipient to a sub-recipient for the sub-recipient to perform substantive programmatic work included in an award received by the recipient. It does not include payments to a contractor for procurement actions (i.e. Personal Service Agreements and purchase orders used to procure supplies and equipment.)

Sub-Recipient

The party that receives a sub-award to perform substantive programmatic work under an award made to a recipient (does not include an individual that is a beneficiary of such program.)

Role:

• Perform the work set forth in the sub-award scope-of-work in accordance with the sub-award terms and conditions;

• Notify PI/PD and OSP of all issues and concerns related to sub-recipient’s performance and compliance;

• Comply with all requests for information related to the performance of the sub-award; and
Maintain a system of records related to the performance of project work in sufficient detail to permit WVU/WVURC and sponsor to evaluate sub-recipient’s technical and financial performance under the sub-award.