Subawards

Invoices from the subawards will first be sent to the invoice coordinator at [email protected] for review and tracking, then to the PI for additional review and approval. Once PI sends approval to the invoice coordinator, it is sent to Accounts Payable for processing. Please note that Northeastern is a net 30 institution i.e., a check will be disbursed from the Accounts Payable Office 30 days after the invoice date.

Subrecipient invoices must be based on actual expenses incurred by the subrecipient unless noted otherwise in the subaward agreement.

The Northeastern PI must approve all subaward invoices to attest that all subrecipient charges appear reasonable and the progress to date on the project is satisfactory.

If your subaward is more than one year in length, a subaward amendment will be needed. Please submit a Subaward Request Form for year two of the subaward (and for each subsequent year) approximately one month prior to the year two start date, if possible. Be sure to include the year two line item budget and SOW (if different from year 1).The subaward amendment agreement with the cumulative subaward dollar amount will be drafted by the subaward manager and sent to the subrecipient for review, negotiation, and signature. The subaward will then be reviewed and signed by NU-RES. The PO/Encumbrance will be modified by the subaward manager to reflect the new subaward amendment amount.

1. The period of performance of a subaward cannot start earlier or end later than the period of performance of the main grant award.
2. Prior approval will be needed from Northeastern (and possibly from the Sponsor) for: changes to the scope of work; a new principal investigator; change in period of performance; significant changes to the budget.
3. A final report of expenditures must be submitted to Northeastern normally within 60 days (or as otherwise stated in the subaward agreement) of the period of performance end date.
4. Conflict of Interest – Northeastern PI and subrecipient PI must disclose any financial interests that could pose a conflict with their professional obligations to the University before a subaward is issued. Investigators who apply for or receive PHS (Public Health Service) funding must now adhere to new Financial Conflict of Interest (FCOI) regulations. Please be advised that NU-RES is unable to process new proposals or awards for PHS funded researchers until the required training and disclosure are completed. Please visit: the FCOI page for more information.
5. Monitoring – All subawards require risk assessment and monitoring to ensure that they comply with Federal regulations and with the awarded subaward terms. In addition, non-profit and foreign subrecipients will be asked annually to provide their most recent financial audit as part of the monitoring process.
6. Closeout – Please remind each of your subrecipient to submit a final invoice, final progress report, and final invention statement (if any) within the time period stated in the subaward agreement. Final invoices must be paid before the grant closes. Make sure that any remaining PO encumbrances are removed from the grant budget prior to close. A NU-RES Financial Analyst will send a comprehensive Grant Closeout Checklist to you several weeks prior to the grant end date.

In some cases, it may be difficult to determine the difference between a Subrecipient and Contractor (Vendor). However, if you have any questions when preparing a proposal budget, please contact your NU-RES grant officer for guidance. The checklist in this link will help differentiate the two.

Definitions from Uniform Guidance (2 CFR, Part 200):

Subrecipient:
§200.93 Subrecipient means a non‐Federal entity that receives a subaward from a pass‐through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding

Contractor:
§200.23 Contractor means an entity that receives a contract as defined in §200.22 Contract.
§200.22 Contract means a legal instrument by which a non‐Federal entity purchases property or services needed to carry out the project or program under a Federal award.

For questions or clarification about the subaward process, please contact via email [email protected].