Faculty & Staff

The arrangements for subaward management in international operations vary from project to project, depending on the scale and risk associated with the project. Generally, however, subaward management is complex and requires robust administrative and financial systems.

The following checklist is a management tool for implementing the essential elements of subaward and subrecipient management in higher-risk operations. PIs and Country/Project Directors may select from the checklist those elements that apply in their context and make their own list to guide staff engaged in subaward management. In ICAP SOPs, the reader is referred to an extensive resource for subaward management.

Responsibilities

• Name one or more Columbia University staff members explicitly as the liaisons between the University and the subrecipient organization, with clearly defined responsibilities in the areas of both financial and technical oversight
• Maintain electronic and physical records of all documentation and communications pertaining to each subaward, and follow Columbia University’s and the funding agency’s record retention policy

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New Subawards

• Collaborate with the Department Administrator and RA and, where applicable, the CTO when making arrangements for any new subaward, providing them with copies of the statement of work (also known as the Scope of Work - SOW), budget, budget justification, and other documentation specified in Appendix A to the University’s Policy on Sponsored Project Subawards
• Establish subawards for periods no longer than one year, renewable for additional periods as appropriate
• Confirm that prospective subrecipients are not among debarred vendors listed on the “Excluded Parties List System”
• Obtain certification from a subrecipient that it has not and will not support terrorist acts (see Vendor Restrictions and Debarment)
• For renovation subawards, issue invitations for bids (IFBs) when there is reasonable expectation of more than one qualified bidder
• Complete a Sole/Single Source Justification Form (available in Appendix 17 of the ICAP SOPs) in the case of non-competitive procurements
• Conduct a risk assessment before executing a Risk Assessment Subaward (see the University’s Policy on Sponsored Project Subawards for the definition and procedure)
• For all other subawards, conduct an on-site pre-award assessment of each potential subrecipient (for more extensive assessments, consider using the Subrecipient Assessment Form in Appendix 63 of the ICAP SOPs)
• Have an authorized official of the subrecipient organization sign final versions of SOWs and budgets to indicate their concurrence with the contents
• Collect complete and accurate contact and bank account information for each prospective subrecipient
• Work with the Department Administrator and RA or the CTO to obtain funding-agency approval for new subawards or major changes to existing ones, including no-cost extensions (NCEs) and cost extensions (continuations)

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Subaward Execution and Payment

• Take into account that from the time the documentation for a new subaward or subaward amendment is submitted to New York until the time a payment is issued to the subrecipient typically takes two to three months, and plan accordingly
• Inform subrecipients that Columbia University requires formal notification of any change in bank accounts (e.g., opening and closing accounts, replacement or new signatories on the account, and revised bank information that is required for wire transfers)
• Wait to process advance requests until the PI or Country/Project Director has in hand the expenditure and technical reports required from the subrecipient

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Post-Award Management

• Provide subrecipients with training in subaward management at the initiation of that agency’s first subaward
• Review all subrecipient invoices or expense reports, comparing them to the subaward budget and disallowing unreasonable, unallowable, or unallocable costs (see specific requirements in Appendix D to the University's Policy on Sponsored Project Subawards)
• Sign-off on all invoices and expense reports, and retain copies in the department/center files (see specific requirements in Appendix D to the University's Policy on Sponsored Project Subawards)
• As necessary to evaluate subaward implementation, visit subrecipients’ project sites regularly to monitor program performance, provide technical assistance, ensure subrecipient conformance with their SOWs, and ensure awarded funds are used for authorized purposes
• Document technical and financial visits to subrecipients (consider using the ICAP SOPs’ forms for Site Visit Reports)
• Through the Department Administrator and RA or the CTO, obtain funding agency approval prior to the subrecipients’ making expenditures for restricted items (e.g., in the case of USG funding, expenditures for building alterations and renovations, subawards to other organizations, consultants, international travel, and vehicles and other major equipment)
• Require that, where applicable, subrecipients maintain a property log and submit it on an annual basis with the final expenditure report
• Require subrecipients to submit effort-reporting certifications, documenting work on University-funded activities
• Notify the Department Administrator and RA or the CTO of any developments that have a significant impact on the activities supported by the subaward, including any problems, delays, or adverse conditions that may materially impair the subrecipient’s ability to meet the objectives identified in the subaward SOW

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Subaward Extensions and Close-Out

• Notify the subrecipient 30 days prior to the expiration of a subaward and, as appropriate, facilitate their requesting a no-cost extension (NCE) or cost extension (continuations)
• Send a close-out letter to the subrecipient 30 days prior to the end date of a subaward, if it has been determined that the subaward will not be extended
• Formally close out the subaward within 60 days of the conclusion of the period of performance, unless RA or the CTO grants an extension of time (see specific requirements in Appendix F to the University's Policy on Sponsored Project Subawards)

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