Subaward Contracting and Monitoring
As per Uniform Guidance requirements, pass-through entities are directly accountable to the sponsor for the subrecipient’s performance and compliance. Hence, proper monitoring must be performed.
Pass-through entities must monitor the activities of subrecipients to ensure that the subaward is used for authorized purposes, subaward performance goals are achieved, and the subrecipient is in compliance with Federal statues, regulations, and the terms and conditions of the subaward (eCFR 200.331).
Pass-through entity monitoring of the subrecipient must include:
- Reviewing financial and performance reports;
- Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award
Subaward Agreement Development
To initiate a subcontract agreement request, use following link: External Subcontractor Generator Form-Grants
Step 1: PI works with Pre-Award services to develop, negotiate and finalize contracts with sub recipient.
Step 2: Pre-Award services works with general counsel, as needed, to execute signed contract and sends to PI.
Step 3: Upon receipt of executed contract, department personnel submits the requisition (within 3 days) to request the purchase order.
If agreement is over $25K, two requisitions need to be entered for subcontracts to be in compliance with 2CFR200
- 1st Req: up to $25,000 use account code 756110 (Subcontract <= 25K)
- 2nd Req: Remaining balance above $25,000 use account code 756111 (Subcontract > 25K)
- Subcontract requisitions are submitted to post-award for approval
Subcontract requisition must not be entered without a fully executed agreement. The Subaward must be uploaded as support to the requisition request.
Subagreement and Purchase Order (PO) must be in place for subrecipient to begin work. They will need the purchase order number to adequately invoice NJIT for payment of services/work rendered. These invoices will need to be submitted to Apinvoices@njit.edu with the PO number indicated on the invoice. Otherwise, they run the risk of payment delays.
The project PI and departmental research administrators are required to ensure that invoices from subrecipients are reviewed before they are approved for payment. Project and invoice monitoring includes the following steps:
- Reviewing invoices against the approved budget and verifying that costs are appropriate for the work performed;
- Verifying that costs are in alignment with cost principles;
- Ensuring that invoicing is occurring according to the schedule outlined in the terms and conditions of the subaward;
- Ensuring that subrecipients submit a final invoice for project expenses at the end of the project, and such an invoice is marked “final.”
The PI approves all subrecipient invoices for payments via eMerchant.
Policy: Subcontract and Contractual Agreement Management
Resource: eCFR 200.331 Subrecipient and contractor determinations