Roles & Responsibilities

Principal Investigator (PI)

  1. Determines that collaboration is needed and identifies the appropriate subrecipient based on scientific considerations, performance capability and record, cost and resources.
    Documents the rationale for the selection of the subrecipient as part of the proposal.
  2. Develops a budget and SOW for the proposal in consultation with the subrecipient.
  3. Authorizes OSP to initiate and/or amend subcontracts.
  4. Works with OSP to ensure appropriate subcontract terms are developed for the subrecipient relationship.
  5. Obtains, reviews and evaluates all specified technical reports and other deliverables from the subrecipient in a timely manner. Ensures copies of technical reports and other support documenting technical progress remain available.
  6. Performs periodic site visits if necessary and/or monitors using other methods as needed to evaluate progress toward scientific objectives. Retains documentation of these actions.
  7. Approves invoices for payment based on Department Administrator’s sign off. Requests additional support or clarification from the subrecipient as needed.
    • PI approval certifies that expenses are appropriate and reasonable in relation to the technical progress and that the cumulative expenses are within total budget.
    • For milestone/deliverables invoices, PI approval certifies that the milestone/deliverable has been completed satisfactorily.
  8. Alerts OSP and RCA to any issues related to the subcontract, including technical performance, regulatory compliance concerns and budget/financial considerations.
  9. Upon receipt of final invoice and technical and other reports, ensures timely closeout of subcontracts.

Department Administrator (DA)

  1. Assists PI and OSP in requesting documentation and developing contractual terms for the subrecipient relationship.
  2. Assists PI in monitoring responsibilities and maintaining supporting documentation of costs and deliverables, especially of those subrecipients identified as having greater risk.
    Such monitoring could include site visits, reports or regular contact.
  3. Reviews invoices from subrecipients for adherence to budget guidelines. The Department Administrator’s signature on the invoice indicates the review has occurred.
  4. Seeks clarification or support from subrecipient for any unusual, miscellaneous, seemingly excessive or other charges invoiced by the subrecipient.
  5. Works with PI and OSP on modification of subcontracts as needed.
  6. Assists PI with timely closeout of subcontracts.

Office of Sponsored Projects (OSP)

  1. Determines at proposal stage, in consultation with the PI, whether a subrecipient or vendor relationship exists; ensures that adequate documentation regarding the selection process is on file.
  2. After prime award is executed, contacts department to initiate subaward process.
    • Completes risk assessment matrix prior to negotiation and execution of subcontract agreement.
    • If intended subrecipient is not in Federal Audit Clearinghouse, requests organization information from subrecipient.
    • Contacts RCA to craft appropriate contractual language to reduce financial risk for subrecipient not in the Federal Audit Clearinghouse or in a medium or high-risk category.
    • Advises PI, DA, and RCA of results if high level of risk is assigned to the subawardee.
  3. Determines appropriate contractual vehicle (cost reimbursement, fixed price, other).
  4. Negotiates, modifies and executes subcontract documents.
  5. Prepares the appropriate subcontract based on the statement of work, risk assessment and the sponsor’s terms and conditions in the prime award.
  6. Contacts department/PI if any additional information is necessary to complete the subcontract.
  7. Ensures terms and conditions include dates of service, re-budgeting authorities and cumulative costs authorized.
  8. Ensures subcontracts are complete and incorporate sponsor’s required flow-down provisions, including audit requirements under OMB Circular A-133.
  9. Notifies PI about any special issues relating to the terms of the subcontract.
  10. Prior to issuing modifications, reviews risk assessment status to ensure any needed changes to risk level are appropriately reflected in the subcontract amendment.
  11. Initiates the process to prepare, issue and execute modifications to the subcontract.
  12. Notifies PI, DA, dean’s office and RCA that a subcontract agreement has been issued or modified and distributes copies of the agreements to all parties.
  13. Provides prompt response to PI in the event performance or programmatic issues arise during the period of performance; works with subrecipient to identify and implement a corrective action plan; notifies sponsor as needed.
  14. Maintains a system to identify current subrecipients in coordination with RCA.

Research and Cost Accounting (RCA)

  1. If intended subrecipient is not in Federal Audit Clearinghouse or is in a medium or high-risk category, works with OSP to draft appropriate contractual language to manage financial risk.
  2. Provides separate accounting within the university’s accounting system to facilitate tracking of subcontract costs.
  3. Reviews invoices prior to payment to ensure that all invoices are consistent, within project period and the cumulative amount of the invoice does not exceed the total amount of the subcontract.
  4. Provides prompt assistance to PI in the event budgetary/financial issues arise during the period of performance; works with PI and subrecipient to resolve outstanding financial matters.
  5. Reviews OMB Circular A-133 reports for subrecipients or obtains an annual certification from each subrecipient for compliance with the Circular.
    • Follows up on instances of subrecipient noncompliance with annual certification requirements.
    • Follows up with subrecipients regarding appropriate and timely corrective action on findings related to the university’s subcontracts.
    • Conducts periodic review of invoice support based on risk assessment.