Subawards

Under the Uniform Guidance (2 C.F.R. §200), an organization is considered a subrecipient of a federal award when it:

1. Determines who is eligible to receive what financial assistance;
2. Has its performance measured against whether the objectives of the federal program are met;
3. Has responsibility for programmatic decision-making;
4. Has responsibility for adherence to applicable federal program compliance responsibilities; and
5. Uses the federal funds to carry out a program of the organization as compared to providing goods and services for a program of the pass-through entity.

Under the Uniform Guidance (2 C.F.R. §200), an organization is considered a contractor (vendor) when it:

1. Provides goods and services within normal business operations;
2. Provides similar goods and services to many different purchasers;
3. Operates in a competitive environment;
4. Provides goods or services that are ancillary to the operation of the Federal program; and
5. Is not subject to compliance requirements of the Federal program.  

Not all of these characteristics will be present in every case. According to the Uniform Guidance, judgment should be used in each individual case in determining whether an entity is a subrecipient or a vendor.

Contractor (aka Vendor) – Contractor means an entity that receives a contract. A contract is a legal instrument by which a non-federal entity purchases property or services needed to carry out the project or program under a federal award. (Uniform Guidance §200.22, §200.23)

Subaward – Subaward means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract (Uniform Guidance §200.92)

Subrecipient – Subrecipient means a non-federal entity that receives a subaward from a pass-through entity to carry out a part of a federal program; but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency (Uniform Guidance §200.93)

Subawards have a pre-award and post-award lifecycle, with different considerations and processes at each stage:

The following forms and guidance is provided to assist departments ensure proper stewardship of sponsor funds. All forms are optional; however, additional monitoring efforts shoudl always be implements if there is any question about the subrecipient's ablity to ensure proper use and financial management of sponsor funds during any stage of the award.

Department Reference

Form Name	Description
Stages of Subrecipient Monitoring	The Stages of Subrecipient Monitoring provides an overview of the monitoring activities performed at each stage of a subagreement.
Roles and Responsibilities Chart	The Roles and Responsibilities Chart provides an overview of the general subrecipient monitoring process. Due to the varying nature of subagreements, responsibility for a specific subrecipient monitoring task may differ.

Initial Award Stage Monitoring

The initial set-up phase includes activities performed prior to issuing a subagreement to a third-party organization and during award set-up. Subrecipient monitoring activities at this stage are generally related to choosing a subrecipient who has the technical/financial resources to fulfill the proposed scope of work. If the PI or department questions whether or not the subrecipient has acceptable business practices, the following tools can be utilized when deciding whether or not a subrecipient is appropriate for the proposed work or to determine which risk mitigation strategies the department should implement.

Form Name	Description
Risk Assessment Matrix	The Risk Assessment Matrix is used by departments to assess the level of risk posed by the subrecipient. If Parkland is issuing a subagreement to an organization with whom the Institution has no previous relationship, it is advised to perform a risk assessment at the award stage to determine if a monitoring plan is needed.
Subrecipient Profile Questionnaire	The Subrecipient Profile Questionnaire is used to help determine a subrecipient organization’s financial and management strength, which helps assess risk and dictates the monitoring plan for subrecipients.
Subrecipient Monitoing Plans	The Subrecipient Monitoring Plans gives examples of subrecipient monitoring plans to implement based on a subrecipient’s perceived riskiness.

Ongoing Monitoring

Ongoing monitoring includes activities undertaken to monitor the subrecipient’s administration, billings and scientific progress of an active subagreement as well as on-going risk assessments. The following tools can be used as a guide and for documentation of subrecipient monitoring efforts:

Form Name	Description
Welcome Package for New Subrecipients	The Welcome Letter for New Subrecipients introduces new subrecipients to Parkland’s business practices and sets the expectations for complying with Parkland’s policies. The Sample Invoice demonstrates the elements required for a complete invoice when billing subagreement expenses.
Invoice Monitoring Guide	The Invoice Monitoring Guide is a list of 10 questions for departments to consider when monitoring invoices for completeness and compliance with Parkland’s policies.
Subrecipient Monitoring Record	The Subrecipient Monitoring Record is used to document monitoring efforts and maintain an audit trail. Use of the tracking record is encouraged at all risk levels but is strongly encouraged for Medium and High risk subrecipients.
Problematic Subrecipient Letter	The Problematic Subrecipient Letter is sent to subrecipients at the request of a member of the Subrecipient Monitoring Committee when a subrecipient is identified for late billing, communication difficulty, or any other factor related to noncompliance or potential noncompliance.

FDP subcontract templates