UConn SPS Subawards Process Overview (PDF)

Subrecipient agreements, either subcontracts or subawards (from here on, both are referred to as “subawards”) are a mechanism for passing funding provided by a prime sponsor through to a subrecipient for the purpose of carrying out a portion of the scope of work of the project. SPS works closely with principal investigators (PIs), fiscal officers (FOs), and department administrators (DAs) in assessing risk, issuing agreements, and monitoring subrecipient progress. When issuing a subaward agreement or amendment, the “subrecipient organization” is the recipient of the pass-through funding; UConn is known as the “pass-through entity (PTE).”

Once a prime award is finalized, and the required documentation from the subrecipient is in place (either at the time of UConn’s prime proposal, or when the need for a subaward has been identified and all appropriate sponsor prior approvals have been obtained), UConn can pass the funding through to the subaward recipient. Subawards are then monitored to ensure compliance with the terms of the subaward and prime agreement. The steps below occur only after a prime award has been received and an account established. For additional information about assembling subaward materials for inclusion in a UConn prime submission, please see SPS’ Proposal Contents page.

NEW Subaward Agreements (Included in Prime Proposal Submission)

STEP 1. SPS Notifies PI and Department of Award Action

SPS’ Award Setup team sends notifications to the principal investigator and department fiscal officer once compliance has been verified and a KFS account has been established. This notification will include a list of subrecipients and their proposed budget amounts and periods of performance.

STEP 2. Fiscal Officer Initiates Purchase Requisition in HuskyBuy

UConn’s HuskyBuy e-procurement system is used to obligate funds from a sponsored programs financial account for the purchase of goods and services. For subaward agreements, HuskyBuy Purchase Requisitions are created by the department fiscal officer (FO) to allocate funding and request SPS drafting, issuance, and execution of a new subaward agreement. Once the agreement has been executed (signed by both the subrecipient and UConn’s authorized signatory), the Purchase Requisition is activated by SPS; the resulting Purchase Order allows the subrecipient to invoice according to the terms of the subaward.

• SPS’ HuskyBuy Subaward Actions Job Aid provides full instructions for initiating a subaward-related Purchase Requisition (for new subawards) or Purchase Order Action (for subaward amendments).
• SPS’ HuskyBuy Subaward Actions Quick Guide provides a listing of subaward-related actions corresponding to common prime award activities.
• Please visit Resources for UConn Suppliers/Recipients of Payments for additional information on how subrecipients can register as suppliers in the HuskyBuy system. Please note that a completed and signed Form W-9, along with an active SAM.gov registration, are required.

STEP 3. SPS Reviews Documents and Conducts Risk Assessment

SPS staff conduct a thorough review of all subrecipient proposal documents, audit reports, and additional information (including the Subrecipient Profile Questionnaire for entities that are not current members of the Federal Demonstration Partnership). These documents are used to complete a risk assessment, as required by 2 CFR 200.332. Based upon the outcome of the risk assessment, additional language may be incorporated in the draft subrecipient agreement (detailed invoicing requirements, submission of more frequent invoicing, etc.).

STEP 4. SPS Issues Subrecipient Agreement

SPS staff provide the draft agreement to the PI and FO for review and approval. Once approved by the PI, the draft agreement is forwarded to the subrecipient for review and signature. UConn utilizes the agreement templates developed by the Federal Demonstration Partnership to issue federal subawards. While these typically do not require revision, subrecipient requests for negotiation will be considered; this is also true of non-federal subawards, which are issued using the UConn narrative template.

STEP 5. SPS Approves Purchase Requisition

Once the agreement has been signed by an authorized signatory of both UConn and the subrecipient, SPS staff approve the purchase requisition, resulting in a Purchase Order. The Purchase Requisition number serves as the Subaward Agreement Number appearing on the subaward agreement, and is used by the subrecipient when submitting invoices for payment.

STEP 6. SPS Distributes Fully Executed Agreement

SPS staff provide the Purchase Requisition and KFS numbers, along with the fully executed agreement, to the subrecipient, and update the InfoEd Agreement record to reflect its completion.

STEP 7. PI and Department Monitor Subrecipient Performance

Principal investigators and department grant administrators should review invoices from subrecipients to ensure that expenditures are consistent with the proposed budget, costs are incurred within the period of performance and are allowable, expenses are aligned with technical progress, and cost sharing, if required, is appropriately reflected. If the subaward is issued from a federal prime award, the following invoice certification must be included:

“I certify to the best of my knowledge and belief that the information provided herein is true, complete, and accurate. I am aware that the provision of false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil, or administrative consequences including, but not limited to violations of U.S. Code Title 18, Sections 2, 1001, 1343 and Title 31, Sections 3729-3730 and 3801-3812.”

Amendments to Existing Subaward Agreements (Included in Prime Proposal Submission)

STEP 1. SPS notifies PI and Department of Award Action

SPS’ Award Setup team sends notifications to the principal investigator and department fiscal officer once compliance has been verified and a KFS account has been established. This notification includes a list of subrecipients and their proposed budget amounts and periods of performance. Actions resulting in a need for amendment of a subrecipient agreement include the addition of incremental funding, no-cost extensions, etc.

STEP 2. Fiscal Officer Revises Existing HuskyBuy Purchase Order

Purchase Order Amendments (POAs, also known as Purchase Order Revisions) are used to revise existing HuskyBuy Purchase Orders for purposes such as addition of funds, extension of periods of performance, etc. Once submitted, the POA routes to SPS Post-Award for review and approval.

STEP 3. SPS Reviews Documents and Conducts Risk Assessment

SPS staff conduct a thorough review of all subrecipient proposal documents, audit reports, and additional information (including the supplemental Subrecipient Profile Questionnaire for entities that are not current members of the Federal Demonstration Partnership). These documents are used to complete a risk assessment, as required by 2 CFR 200.332. Risk assessments are revisited with each subsequent amendment to ensure that no further action or risk mitigation is necessary.

STEP 4. SPS Issues Bilateral Amendment

SPS staff draft an amendment and provide to the PI and FO for review and approval. Once approved by the PI, the draft amendment is forwarded to the subrecipient for review and signature.

STEP 5. SPS Approves Purchase Order Action

Once the agreement has been signed by an authorized signatory of both UConn and the subrecipient, SPS staff approve the Purchase Order Amendment, resulting in an update to the existing Purchase Order. The original Purchase Requisition number/Subaward Agreement Number should continue to be used by the subrecipient when submitting invoices for payment.

STEP 6. SPS Distributes Fully Executed Amendment

Distribution of fully executed amendments takes place as for new agreements once both UConn and the subrecipient have signed the amendment. SPS staff provide the Purchase Requisition and KFS numbers, along with the fully executed amendment, to the subrecipient, and update the InfoEd Agreement record to reflect its completion.

STEP 7. PI and Department Continue to Monitor Subrecipient Performance

Principal investigators and department grant administrators should continue to review invoices from subrecipients to ensure that expenditures are consistent with the proposed budget, costs are incurred within the period of performance and are allowable, expenses are aligned with technical progress, and cost sharing, if required, is appropriately reflected. If the subaward is issued from a federal prime award, the following invoice certification must be included:

“I certify to the best of my knowledge and belief that the information provided herein is true, complete, and accurate. I am aware that the provision of false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil, or administrative consequences including, but not limited to violations of U.S. Code Title 18, Sections 2, 1001, 1343 and Title 31, Sections 3729-3730 and 3801-3812.”

New Subaward Agreements – NOT Included in Prime Proposal

Please consult with your assigned Post-Award/Award Management contact to determine whether sponsor prior approvals are required to add a subaward/subcontract after award. In most cases, a full subrecipient proposal will be required, to include a Subrecipient Information & Compliance Form, scope of work, budget, budget justification, and key personnel documents. An internal budget revision may also be required. Once all documents have been assembled and prior approvals received, subaward review and drafting follow the same steps outlined above.