Establishing a Subrecipient Agreement

UAB is responsible for the programmatic and financial monitoring of its subrecipients. A subrecipient is a third-party organization performing a portion of work on a sponsored project received by UAB. The following procedures have been developed to ensure that subrecipient agreements are developed and conducted in compliance with all applicable laws, regulations, and terms and conditions included in UAB’s prime award(s).

Prior to submission of a grant or contract proposal to the sponsor:

  1. The UAB Principal Investigator (PI) must identify the subrecipient in the proposal.
  2. The proposal must contain the subrecipient’s scope of work and budget in sufficient detail to comply with the sponsor’s requirements and to allow UAB to evaluate the ability of the subrecipient to maintain compliance with the terms and conditions of the award.
  3. The subrecipient’s proposal must include a letter of intent, signed by the subrecipient’s institutional official, stating that the subrecipient intends to participate as a UAB subrecipient.
  4. The proposal must contain a copy of the subrecipient’s most recent Colleges and Universities Rate Agreement or other federally negotiated rate agreement if the subrecipient’s budget requires reimbursement of facilities and administrative (F&A) costs based on its federally negotiated rate. If the sponsor’s policy limits the reimbursement of F&A costs, the subrecipient must agree to comply with the sponsor’s policy. Include the policy with the proposal.

Once the proposal has been awarded:

  1. UAB will not knowingly issue an agreement to a subrecipient or its key personnel who are debarred, suspended, or otherwise prohibited from receiving federal grants or contracts. To prevent such issuance, the Office of Grants and Contracts Administration (OGCA) will check the debarment and suspension status of the subrecipient and all key personnel named in the budget.
  2. Regulatory approvals, such as Institutional Review Board (for humans as research subjects) and Institutional Animal Care and Use Committee (for animals as research subjects) approvals, must be obtained prior to issuing a subrecipient agreement.
  3. OGCA will write, negotiate, execute. and distribute the subrecipient agreement and any amendments to the subrecipient agreement on behalf of UAB.

 

Audit Requirement

As a Pass-Through Entity, UAB is required to ensure that Subrecipients comply with the audit requirements found in Office of Management and Budget (OMB) Uniform Guidance (UG) 2 CFR part 200, subpart F. The audit requirements prescribed by 2 CFR Part 200.501 include:

  • Audit required - a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year.
  • Single audit - a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514 except when it elects to have a program-specific audit conducted.
  • Program-specific audit election - when an auditee expends Federal awards under only one Federal program (excluding R&D) and the Federal program's statutes, regulations, or the terms and conditions of the Federal award do not require a financial statement audit of the auditee, the auditee may elect to have a program-specific audit conducted in accordance with § 200.507. A program-specific audit may not be elected for R&D unless all of the Federal awards expended were received from the same Federal agency, or the same Federal agency and the same pass-through entity, and that Federal agency, or pass-through entity in the case of a subrecipient, approves in advance a program-specific audit.
  • Exemption - when a non-Federal entity expends less than $750,000 during the non-Federal entity's fiscal year in Federal awards it is exempt from Federal audit requirements for that year, except as noted in § 200.503, but records must be available for review or audit by appropriate officials of the Federal agency, pass-through entity, and Government Accountability Office (GAO).

 

Submitting Sub-recipient Invoices for Payment

  1. All invoices received from the sub-recipient should be sent to the PI's office for processing.
  2. The PI’s office will review the invoices to ensure that all costs comply with the guidelines of the award. Documentation should be attached that supports the request for payment.
  3. The PI’s office will include a “Certificate of Sub-recipient” form, signed by an authorized representative of the institution, with each invoice.
  4. The PI’s office will attach a “Certificate of UAB Personnel” form, signed by the PI or the award manager, along with the supporting documentation for payment of each invoice. If the sub-recipient invoice is 120 days overdue, the Dean is required to countersign the “Certificate of UAB Personnel” form.
  5. Once the PI’s office has reviewed all documentation, a payment request can be submitted through the approval path. Grants and Contracts Accounting (GCA) will receive the payment request to review the invoices and supporting documentation and ensure that both certificates are attached. GCA will also make sure that the request for payment is within the timeframe of the prime award and that the expenditures do not exceed the amount of the sub-recipient’s agreement.
  6. GCA will then process the payment request.