Subawards

When the University is awarded a sponsored project agreement in which a substantial portion of the work will be accomplished by another institution or organization, the policies and procedures set forth in this section apply. The nature of the relationship between Penn and the outside entity will determine the contracting mechanism used. If a PI at the outside entity is contributing intellectually and independently supervising the activities, a Subcontract will be issued. However, if the outside entity is providing consulting or other services and is not contributing as a collaborator on the project, a purchase of services (vendor) agreement may be more appropriate.

Subawards cannot be used for routine purchases of equipment or support services.

When collaborating with another investigator who is contributing intellectually to the project, a subaward agreement is required. Subawards serve to establish expectations for contributions to the project and to flow down requirements from the funding sponsor to the subaward recipient.

Upon receipt of an award from the sponsor, it is the responsibility of the PI to request a subaward in the Research Inventory System (RIS). Either the PI or the BA begins the request in RIS by identifying the subaward recipient, providing a statement of work and a budget, as well as any IRB or IACUC approvals covering the subrecipient project. While a BA can begin this process, ORS cannot begin to create a subaward until the PI approves the RIS record.

The subaward request is electronically routed through RIS to verify regulatory compliance and subrecipient monitoring. In accordance with federal regulations, ORS reviews the subaward recipient’s audit report and verifies that the institution and individual are eligible to receive federal funds. ORS is responsible for writing the subaward and circulating for signatures. Once the agreement is signed, RIS sends an email notification to the PI and the BA. The BA will receive an email indicating that it is appropriate to establish a PO.

The PI can request modifications to existing subawards using the same process as described above. Throughout the project, the subrecipient is required to submit invoices as outlined in the agreement. It is the responsibility of the PI to monitor the progress of the subrecipient and ensure that the work is being performed satisfactorily, reports are submitting on time, and invoices are appropriate based on the work being performed. The BA is responsible for coordinating payment of approved invoices, requesting additional documentation as needed, and maintaining records sufficient to support the expenditures. The PI is responsible for coordinating technical reporting.

At the end of a subaward period of performance, the subrecipient is expected to submit a final statement of cumulative costs no later than 60 days after the end of the budget and project period date. The subrecipient is also responsible for reporting any inventions resulting from the subaward to the BA.

It is the BA’s responsibility to request and maintain a record of the subrecipient’s expenses. The BA should also make ORS aware of any inventions reported by the subrecipient. ORS is responsible for requesting final invention reports and providing them to sponsors. The PI is responsible for coordinating preparation and submission of any required final technical reports (See Sponsored Projects Policies Nos. 2131 and 2135.)