Embedded Files
A subaward is a formal written agreement made between PSU and a "Subrecipient" to perform a portion of the statement of work under an award, issued to PSU by an external sponsor. A subaward must include a clearly defined, intellectually significant statement of work to be performed by the subrecipient, who performs the work using its personnel and using its own facilities and resources.
As a recipient of funding from sponsors, PSU is obligated in its role as primary recipient of funds to undertake certain stewardship activities as well as comply with federal, state and local regulations, as well PSU policies. Although PSU has assigned the responsibility for conducting a portion of the work to a subrecipient, PSU remains ultimately responsible to their sponsor for management of funds and meeting performance goals. Thus, the monitoring of technical and financial activities associated with a subrecipient is an integral part of PSU’s stewardship of sponsor funds.
Subaward Agreements are generated and negotiated by SPA. To initiate a new subaward agreement, complete the Request for Subcontract Document Form and send it via email to subs@pdx.edu. To request an amendment to an existing agreement, complete a Subaward Amendment Request Form and email it to subs@pdx.edu. For additional information regarding the subaward creation process contact the appropriate Grants & Agreements Team (GAT).
Pre-Qualification of Subrecipients: Before issuing a subaward, PSU conducts an assessment of the subrecipient organization’s financial status and internal controls and will establish terms and conditions in the subrecipient agreement consistent with the level of perceived risk. A subrecipient risk assessment may take into account several factors including the subrecipient's audit experience, the prior oversight and monitoring the subrecipient has received, the nature and complexity of the proposed research project, and fiscal maturity of the subrecipient.
Contractors
Contractors
Contractors provide goods or standard services within their normal business operations, charges standardized rates, operates in a competitive market, and does not hold intellectual property rights or scientific authorship over the study's results.
Routine Laboratory Analysis & Assays: Sending biological or chemical samples to an external facility (commercial vendor or core facility) for standard DNA/RNA sequencing, mass spectrometry, or histology using their standard operating procedures (SOPs) for a set per-sample fee.
Survey Administration & Field Data Collection: Hiring a commercial polling or market research firm to recruit participants and administer a pre-designed questionnaire using established, standardized methods.
Custom Software & App Development: Contracting a web or mobile development agency to build a participant-facing app, database, or project website based on technical specifications defined entirely by the Principal Investigator (PI).
Equipment & Facility Rental: Paying hourly machine-time or bench fees to access specialized instrumentation (e.g., cleanroom time, high-throughput screeners, supercomputing clusters, or MRI scanners) where external staff only oversee safe equipment operation.
Transcription, Translation & Editing: Hiring external professional service providers to translate research instruments, transcribe focus group audio recordings, or provide medical/scientific English editing.
Routine Data Processing & Formatting: Paying an external consultant or firm to perform standardized data entry, basic code execution, or formatting tasks without them making decisions on data interpretation or scientific direction.
Animal Housing & Standard Husbandry: Paying an external animal facility for routine care, feeding, and housing of research animals without the external entity managing experimental interventions or protocols.
Subrecipient or Contractor Determination
Subrecipient or Contractor Determination
outine Laboratory Analysis & Assays: Sending biological or chemical samples to an external facility (commercial vendor or core facility) for standard DNA/RNA sequencing, mass spectrometry, or histology using their standard operating procedures (SOPs) for a set per-sample fee.
Survey Administration & Field Data Collection: Hiring a commercial polling or market research firm to recruit participants and administer a pre-designed questionnaire using established, standardized methods.
Custom Software & App Development: Contracting a web or mobile development agency to build a participant-facing app, database, or project website based on technical specifications defined entirely by the Principal Investigator (PI).
Equipment & Facility Rental: Paying hourly machine-time or bench fees to access specialized instrumentation (e.g., cleanroom time, high-throughput screeners, supercomputing clusters, or MRI scanners) where external staff only oversee safe equipment operation.
Transcription, Translation & Editing: Hiring external professional service providers to translate research instruments, transcribe focus group audio recordings, or provide medical/scientific English editing.
Routine Data Processing & Formatting: Paying an external consultant or firm to perform standardized data entry, basic code execution, or formatting tasks without them making decisions on data interpretation or scientific direction.
Animal Housing & Standard Husbandry: Paying an external animal facility for routine care, feeding, and housing of research animals without the external entity managing experimental interventions or protocols.
Why these qualify as contractors: In each case, the entity provides ancillary goods or standard services within their normal business operations, charges standardized rates, operates in a competitive market, and does not hold intellectual property rights or scientific authorship over the study's results.
Subrecipient Monitoring
Subrecipient Monitoring
In order to meet PSU’s obligations to manage subrecipient activity, the following represents the minimum stewardship activities to be performed by PSU with regard to subrecipients of sponsored awards made to PSU.
Each Principal Investigators (PI) will have primary responsibility for monitoring subrecipients to ensure compliance with federal regulations, both prime and subrecipient award terms and conditions, as well as PSU policy.
1. Identify and recommend the means to eliminate or manage any conflict of interest arising from a proposed subaward by PSU to an entity in which PSU or a faculty member has a financial interest or fiduciary relationship.
2. Advise subrecipients of requirements imposed on them by federal laws, regulations of the flow-down provisions of the prime award and any supplemental requirements imposed by PSU. This includes both financial and non-financial reporting.
3. Inform subrecipients when they are subject to regulations as a result of receiving sponsored funds. PSU shall provide the best information available to describe an award to each subrecipient including the Catalog of Federal Domestic Assistance (CFDA) title and number for federal awards, award name and number, award year, the type of award, and the name of the sponsor as required by OMB Circular A-133 or the Uniform Guidance 2 CFR 200.
4. Monitor the costs and activities of subrecipients as appropriate, to confirm that funding provided to the subrecipient is used for purposes authorized in the negotiated agreement and that performance goals articulated in the scope of work are achieved.
5. Upon recipient of an unfavorable audit report from a subrecipient, PSU will confirm that the subrecipient has taken appropriate and timely corrective action. If a material weakness or other reportable condition exists, monitoring of the subrecipient will be more frequent and management actions will be taken as appropriate.
6. Consider whether subrecipient audits necessitate adjustment of PSU financial records.
7. Require each subrecipient to permit the sponsor and/or PSU and its auditors to have access to the subrecipient’s pertinent records and financial statements, as necessary. Where it is not possible to obtain this access, alternate solutions may be devised but generally would require the approval of the primary sponsor.
8. Confirm that subrecipients expending $500,000 or more in federal awards during the subrecipient's fiscal year are compliant with OMB Circular A-133 audit requirements. Identify any material weaknesses or reportable conditions that result from the A-133 audit.
Annual Risk Monitoring: At least annually, Research and Strategic Partnerships gathers updated information and documentation on subrecipient organizations’ financial stability, financial processes, and controls contained in the subrecipients A-133 audit certification letters or annual financial statements. The frequency of monitoring will be determined based upon the specific organization and the nature of the subaward activity.
Paying Subaward Invoices
Paying Subaward Invoices
Review of Invoices should be done for cost-reimbursement subagreements. The subrecipient's invoices showing both current period and cumulative expenses-to-budget are generally required. Evidence of the regular review of invoices by both the PI and the Department Research Administrator (DRA) should be in place and retained on file. "Evidence" can be in the form of PI initials or authorizing signature on invoices, e-mail communications, notes of meetings with the DRA, etc. When the PI approves the subrecipient invoices, the PI is approving the payment and attesting that the charges appear reasonable and progress to date on the project is satisfactory and keeping with the statement of work.
Clarification of Invoiced Charges should be requested by the DRA for explanations of any unusual, miscellaneous, apparently excessive or other charges invoiced by the subrecipient. If the explanations are not sufficient to render a prudent judgment on the allowability of the cost, and the terms of the subcontract permit. A DRA may request detailed justifications from subrecipients. DRAs may also periodically request, if the terms of the subcontract permit, particularly from high-risk subrecipients detailed support for selected invoiced charges to verify their appropriateness and reasonableness. Examples of detailed justifications that may be requested from subrecipients include:
Payroll records/data
Copies of paid invoices showing the cost of items purchased and Vendor Justification Forms if required by Federal contract
Descriptions of services rendered by consultants including hourly rates and time reports
Details of incurred travel charges, stating the purpose, airfare, meals, ground transportation, unallowable costs, etc.
Costs determined to be unallowable or unreasonable should be disallowed
In circumstances where questionable costs remain unresolved, particularly when subcontract terms do not permit requesting supporting documentation, it may become necessary to conduct a definitive audit of all or a portion of questionable costs. In these cases, DRAs may contact SPA for coordination of subsequent actions.
Federal Accountability and Transparency Act (FFATA) Reporting Requirements - Coming Soon
Federal Accountability and Transparency Act (FFATA) Reporting Requirements - Coming Soon
Regulations Impacting Subrecipient Monitoring:
Regulations Impacting Subrecipient Monitoring:
OMB Circular A-133, B.210.f: “The auditee is responsible for ensuring compliance for vendor transactions which are structured such that the vendor is responsible for program compliance or the vendor's records must be reviewed to determine program compliance. Also, when these vendor transactions relate to a major program, the scope of the audit shall include determining whether these transactions are in compliance with laws, regulations, and the provisions of contracts or grant agreements.”
OMB Circular A-133, 510.b: “Audit findings shall be presented in sufficient detail for the auditee to prepare a corrective action plan and take corrective action and for Federal agencies and pass-through entities to arrive at a management decision.”
OMB Circular A-133, 525.a: “The auditor's determination should be based on an overall evaluation of the risk of noncompliance occurring which could be material to the Federal program. The auditor shall use auditor judgment and consider criteria… to identify risk in Federal programs. Also, as part of the risk analysis, the auditor may wish to discuss a particular Federal program with auditee management and the Federal agency or pass-through entity.”
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