When the University serves as the Pass-Through Entity (PTE) with a subrecipient collaborator, the University acts as the sponsor. The PTE is obligated to monitor and confirm the subrecipient’s compliance with the project’s terms and conditions, University policies and procedures, and any other applicable regulations.
This site provides information on proposing and monitoring subrecipients at the University. Specific questions should be directed to your department’s Sponsored Projects Specialist (SPS) or Contracting Manager (CM).
During the proposal phase, it is important to determine if subrecipients will be needed and if so, understanding the specific requirements the sponsor may have for subrecipients. The department and PI works closely with the subrecipient to collect all necessary information for the proposal submission.
Once a prime award has been received and executed, the subrecipient information should be reevaluated based on the agreement and any needed changes to the budget, budget justification, or scope of work should be made. At this point, any applicable compliance components should be completed, such as IRB reliance agreement, IACUC MOUs, etc. Once the subagreement project IDs are established in RAMSeS and ConnectCarolina, the department can submit the Subagreement Initiation Portal (SIP) request to the Contracting team for review and issuance of the agreement to the subrecipient.
After a subaward or subcontract is executed, the department is responsible for monitoring the subrecipient’s technical/scientific progress, reviewing and processing invoice payments, and alerting OSP to any necessary amendments. The department is also responsible for obtaining any necessary closeout documentation from the subrecipient in a timely manner in order to facilitate appropriate reporting to the Prime sponsor.
Federal Demonstration Partnership
The Federal Demonstration Partnership (FDP) is an initiative between select Federal agencies and recipient institutions to reduce the administrative burdens associated with research administration, including issuing subagreements by providing standardized templates.
Electronic Code of Federal Regulations
- CFR Subpart C – Recipient Requirements of Subrecipients
- 910.501 Audit Requirements
- 200.331 – Subrecipient and Contractor Determinations
- 200.332 – Requirements for pass-through entities
- 570.503 Agreements with Subrecipients
Electronic Federal Acquisition Regulations
UNC Office of Sponsored Programs
- Office of Sponsored Programs – 500.11 – Outgoing Subrecipient Agreements
- Office of Sponsored Programs – 500.02 – Departmental Award Management Responsibilities
Please remember that there could be sponsor or project-specific regulations that are applicable to subrecipients as well. It is important to read the Prime Agreement carefully.
|Amendments||Amendments are used to make changes to an existing agreement.|
|Budget||The financial plan for the project or program that the awarding agency or pass-through entity approves during the award process or in subsequent amendments to the award. It is a line item portrayal of the funds needed to complete the sponsored project. This amount should include their institution’s F&A amount. For any Federal subrecipient agreement, F&A will not be taken on it after the first $25,000 for each five-year segment.|
|Budget Justification||The description of the line item budget of the funds needed to complete the sponsored project.|
|Budget Period||The intervals of time, which a project period is divided into, for the obligation of funds based on budgetary, funding, and allocation purposes.|
|Budget Revision||Any change made to the budget during the life of a funded project. The ability to make changes, with or without approval of the Sponsor, are dictated in the award documents. A budget revision may constitute a need for Prior Approval. It is a line item portrayal of the funds needed to complete the sponsored project.|
|Carryover||The unobligated funds remaining at the end of a budget period. These funds may or may not be carried forward to another budget period dependent on Sponsor approval. Obligated, but unliquidated, funds are not considered carryover.|
|Conflict of Interest (COI)||A situation where financial or personal considerations, circumstances, and relationships may compromise or appear to compromise the objectivity of an individual performing research duties or responsibilities.|
|Effective Date||The date when rights and obligations under an agreement become operational. This may not be the same as the date in which an agreement or contract is executed.|
|Letter of Intent||A letter provided prospective applicants to indicating intent prior to the submission of a grant application. The letter usually includes the name, address and phone number of the PI, identifies other key personnel and participating institutions, and prospective funding mechanism. Although a letter of intent is not required, is not binding, and does not enter into the review of a subsequent application, the information that it contains allows institute staff to estimate the potential review workload and plan for the application.|
|Invoice||A list of goods or services provided with a statement of the sum due for the provision of the goods or services.|
|Just-in-Time (JIT)||NIH specific policy that allows the submission of certain elements of a competing application (e.g. Other Support, Research Subjects Approvals) to be deferred until later in the application process, after review when the application is under consideration for funding.|
|New Agreement||A new agreement will be issued when it is the first year of funding to a subrecipient, when it is a new year of funding on prime awards without automatic carryover, and for subagreements on supplemental funding that need to be accounted for separately. Additionally, a new agreement could be required if there is a break in the period of the subrecipient’s performance. If you have a new Project ID, there should be a new agreement to match it.|
|No Cost Extension (NCE)||An extension of time to a project period and/or budget period provided by the Sponsor to complete the work without additional funding or competition.|
|Pass-through-Entity (PTE)||Pass-through entity means an entity that provides a subagreement to another entity to carry out part of an agreement.|
|Prime Sponsor||The sponsor that is providing funds for an agreement that has been passed-through to another entity to complete some of the research. An example of a prime sponsor would be an incoming subcontract awarded by Duke and even if the original award was sponsored by NIH, Duke would be UNC’s prime sponsor.|
|Prior Approval||The written approval by a sponsor evidencing consent in advance of certain activities or specific costs on the part of the recipient.|
|Project Period/Period of Performance||The time during which the recipient may incur new obligations to carry out the work authorized under the award.|
|Proposal/Application||A detailed request for funding prepared in accordance with the sponsor’s instructions and must comply with University policies and sponsor requirements.|
|Recipient||An entity that receives an award directly from an awarding agency to carry out an activity.|
|Scope of Work (SOW)||The aims, objectives, and purposes of a grant application and the tools, technologies, and timeframes needed to meet the grant’s objectives.|
|Subagreement||A subagreement is a legally binding document provided by the University of North Carolina at Chapel Hill (University/UNC) to an outside entity in order for them to carry out part of the scope of work for an agreement received by the University. A subagreement may be provided through any form of legal agreement, including a grant, award or contract, depending on the funding mechanism used for the Prime agreement.|
|Subrecipient||An entity that receives a subagreement from a pass-through entity to carry out part of the scope of work for an award. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency.|
|Subrecipient Monitoring||The requirement and culpability to ensure the compliance of another entity to the rules and regulations of a sponsored project in place of the Sponsor. The Pass-Through Entity then assumes the monitoring responsibility of the sponsor as there is no direct relationship between the Subrecipient and the Pass- Through Entity’s sponsor.|
Subrecipients are incorporated into the University’s proposal as a separate section within the RAMSeS Internal Processing Form (IPF). At the proposal stage, it is important to confirm any specific requirements that the sponsor may have for including subrecipients. Most sponsors require information from the subrecipient similar to what is provided by the University in the main proposal. For assistance in completeing proposals with subrecipients, please see the Subrecipient Proposal Checklist.
RAMSeS Internal Processing Form (IPF)
The following documentation should be uploaded to the RAMSeS IPF for the Prime Agreement:
- Subrecipient Scope of Work
- Subrecipient Budget
- Subrecipient Budget Justification
- Outgoing Subrecipient Letter of Intent (LOI) – revised May 2022
- When sending the LOI form to the subrecipient for completion, include the instructions as well to ensure all fields will be accurately completed.
- Please note that if the subrecipient enters any personnel on the fully executed LOI, those personnel must also be included on the RAMSeS IPF.
- Effective 7/1/2022, only the current version of the Outgoing Subrecipient LOI will be accepted for proposal submissions.
Just In Time/Intent to Fund
It is important to use the time prior to when an award is received to determine if you have the full subagreement package and what (if anything) you will need if or when the Prime award is received. This will reduce setup time.
The required compliance documentation for subagreements varies depending on the elements of your proposal. It is important to be aware of any necessary information needed from the subrecipient in order to comply with Human/Animal Research subjects, intellectual property, and conflict of interest requirements. These review processes take considerable time, which should be taken into account when planning submissions.
Subagreement Initiation Portal (SIP) Process
SIP is an online form designed to streamline the process for requesting subagreement actions and improve their timely execution. SIP provides a one-stop shop to Initiate a subagreement, Amend an existing subagreement, or Respond to Additional Info/Document Requests pertaining to subagreements. Subrecipients may be issued multi-year subagreements only if UNC’s prime agreement was issued with a multi-year performance period. It is essential to provide accurate and complete information in the SIP in order to ensure the timely execution of subagreements.
Subagreement Contracting Team Process
Once the department submits the SIP, the SPS will receive a RAMTracker and review for appropriate documentation, including verifying the correct budgets are loaded in ConnectCarolina. The RAMTracker is then assigned to a Contracting Manager. Upon receiving the RAMTracker, the Contracting Manager will review the request and the information available to make sure they have all necessary components to complete the action.
Compliance & Risk Assessment
This is a list of compliance checks that the Contracting Manager reviews when taking action on a subagreement:.
- Visual Compliance
- SAM membership
- FDP Membership
- Conflict of Interest
- Foreign Entities
- IACUC – MOU needed for all NIH projects with animal subjects
In addition to compliance checks, the Contracting Manager will conduct a risk assessment which includes determining if the subrecipient is domestic or foreign entity, evaluating audit report findings, and determining the percentage of the prime award being obligated to the subrecipient.
The contracting team will utilize this information to draft the appropriate agreement or amendment. They will then issue the draft agreement/amendment to the subrecipient, and act as the point of contact for negotiation with the subrecipient. If the UNC Prime is issued for multiple years, the subagreement may be issued for multiple years of funding as well. Once the Contracting Manager completes compliance checks, they will draft the appropriate agreement.
Finalized, fully executed documents round-out the process and are returned to subrecipient, department, and data management.
Tips for Expediting Subagreements
- Review all documentation from the subrecipient and ensure all information is correct and present. Any changes from the original documentation should be noted.
- Verify budget and justification to ensure that the calculations are accurate and the documents match. Note that budgets should be broken out for each year of the project.
- Ensure the budget matches the anticipated payment method, I.e., fixed price, per patient, cost reimbursable.
- Ensure the scope of work matches the science from the prime and allows the Contracting Manager to understand what the subrecipient is doing. This is important for subagreement drafting.
- Provide all necessary documentation and attachments required for the SIP, do not skip questions/attachments. This delays the review process. Add any additional documents and information to the SIP that may be relevant for review and drafting, including additional terms and conditions that need to be included such as reporting, data sharing, etc.
Administrative actions are those actions that are completed after an executed subagreement is in place.
For more information on the types of Subagreement Amendments, please see this guidance. Here is a list of common reasons for issuing an amendment:
- Change in funding – adding or removing, awarding carryover, deobligations, etc.
- Change in the period of performance – extensions, terminations, etc.
- PI change
- Other administrative or corrective actions
For more information on administering subagreements, see the Subrecipient Award Management Checklist.
OSP incorporates reporting requirements into our subagreements in order to allow us to meet our own reporting requirements with the sponsor. As a result, reporting requirements may vary from project to project based on the terms and conditions of the prime award. Some common requirements include financial, technical/performance, patent/inventions, and property reports. It is especially important for the UNC PI to review the subrecipient’s technical reports and ensure they meet the sponsor’s requirements. If there are any concerns with any reporting requirement, contact your department’s Sponsored Projects Specialist and/or your assigned Sponsored Projects Accountant for financial matters.
Monitoring for compliance throughout the life of the project is important. After the award has been set-up, regularly perform compliance checks and notify your department’s Sponsored Projects Specialist of any changes.
Uniform Guidance details the requirements the University must complete for each subrecipient that receives Federal funding under a University project:
- Evaluation of the subrecipient’s risk of noncompliance
- Obtain and review the subrecipient’s annual audit
- Establish the appropriate level of monitoring for the subrecipient
- Monitor the subrecipient’s activities and compliance throughout the life of the collaboration
In order for OSP to effectively meet these requirements, the department and PI should perform the following at regular intervals:
- Verify the subagreement is fully executed prior to submitting a subrecipient invoice for payment.
- Verify the PI wants to pay the subrecipient invoice. Do not submit the invoice for payment if the PI suspects work is not being completed.
- Verify the invoice meets terms and conditions of the subagreement, including the payment method.
Invoicing & Payment
Departments are responsible for reviewing and processing all of their subrecipient invoices on time and correctly charging them to the appropriate project chartfield string in ConnectCarolina. Please note some key points with subrecipient invoicing & payment:
- Charges NOT subject to F&A, use account 569461
- Charges that are subject to F&A, use account 569486
- Federal sponsors only allow the first $25,000 of each subrecipient agreement to charge F&A per each five-year segment
The department and PI are responsible for collecting and verifying all required closeout information. All required documentation and due dates will be listed in the subagreement. For assistance with closing out a subagreement, please use the Subrecipient Closeout Checklist.
This information is required at the end of the subagreement even if the Prime award is continuing.
- Final technical report
- Final financial report
- Final inventions report (as applicable)
- Final property report (as applicable)
- Award Management Checklist
- Subrecipient Personnel Change – Conflict of Interest
- Amendment Guidance for Department
- Closeout Checklist