Preparing an Outgoing Subaward or Subcontract

Preparation Steps:

Pre-Award (Proposal development stage and prior to submission)

1) Identify the need for a collaborator.

Note: If the subrecipient is slated to receive federal dollars,
they MUST have a DUNS number and be actively registered in
the System for Award Management (SAM) for MUSC to
subaward intended funds.

2) Determine if collaborator is a subrecipient or contractor by completing
the Checklist.

3) If the collaborator is a subrecipient ensure all of the following documents
are completed and uploaded as one combined file to the CayuseSP
Internal Processing Form (IPF):

a) Letter of Intent signed by an authorized institutional official of the subrecipient

b) PHS 398 Form Page 1 ‘Face Page’ (or equivalent, signed by
an authorized official) which contains all the information
needed for both proposal submission and issuance of subawards
(i.e. Subrecipient institution, PI, DUNS, EIN, Institution
address/congressional district, etc.):
https://grants.nih.gov/grants/funding/phs398/phs398.html

c) Statement of work (SOW): the SOW must be clear and contain
a detailed description of the work to be performed by the
subrecipient including proposed timeline and deliverables.

d) Itemized/detailed budget and budget justification for the
subrecipient. Preferred formats:

Subawards.com import into Cayuse 424, in the format of Grants.gov ‘Research & Related Budget’ form for federal
grants with detailed budgets [This PDF form is compatible to
upload directly into Cayuse]:
https://www.grants.gov/forms/r-r-family.html

PHS 398 Detailed Budget Form Page 4, Form Page 5 & Checklist for NIH grants with modular budgets. https://grants.nih.gov/grants/funding/phs398/phs398.html

e) Copy of, or link to, the subrecipient’s federally negotiated F&A rate agreement IF subrecipient is not part of the FDP Expanded Clearinghouse.

f) Biosketches/CVs for key personnel as required by the funding agency.

g) All FCOI documentation as applicable: External Contributor Form, COI Policy Certification Form, and COI Disclosure Form.

MUSC FCOI information and forms: MUSC FCOI, MUSCFCOI Forms (on the Horseshoe website)

If the subrecipient participates in the FDP FCOI Clearinghouse, upload a pdf of the certification to the IPF record.

h) Other documents as specified in the Funding Opportunity Announcement (read carefully), these often include, but are not limited to:

Letters of Support from Key Personnel

Facilities/Resources & Equipment information specific to the subawards institution

Multiple Principal Investigator Plan if an MPI is listed at the subrecipient site

Small Business Subcontracting Plan

Just-in-Time (MUSC has been notified of a potential award)

1) The Departmental Administrators are responsible for collecting the
necessary Just-in-Time documentation for the subawards. These often
include (but are not limited to) the following:

a) Updated Other Support: for all key personnel that lists both Active
& Pending support with the grant that the Just-in-Time request is listed for included.

b) Biosketches for any new key personnel the
subrecipients may be adding

c) Compliance documentation

i. For all studies involving human subjects, proof of human
subjects training is required. If the project is a Clinical
Trial, there must be proof that the 'Good Clinical
Practices' training module has been completed within
the last three years. Free GCP training is available for
those sites that do not have institutional online training
programs for their faculty/staff.
http://grants.nih.gov/policy/humansubjects/training-and-
resources.htm

http://learningcenter.niaid.nih.gov/

ii. IRB (human subjects), IACUC (animal subjects), IBC
approvals, etc.

iii. DUNS number and active registration in the System for
Awards Management (SAM).

Note: MUSC's typical sub-awardees are universities,
but this sometimes delays subawards to entities
that may not be as research-intensive in their
typical activities.

2) Subrecipient's federally negotiated F&A rate agreement or link (if changed since
original submission) IF subrecipient is not part of the FDP Expanded
Clearinghouse.

3) The ORSP Grants Administrator will review and submit the information to
the sponsor.

Post-Award (MUSC has received the award)

1) The ORSP Grants Administrator & Departmental Administrator will
review the award documents to ensure the Subawards Administrator
has everything necessary to issue the subaward.

2) If the subrecipient information has changed from the original application
(e.g. the total award amount is reduced from the proposed budget), the
ORSP Grants Administrator & Departmental Administrator will work
together to complete new paperwork. Often this includes:

a) Receiving updated budgets & budget justifications with the
concurrence of the AOR for the subrecipient institution.

b) Revised Statement of Work if it has changed since the origina
submission.

c) Updating any necessary FCOI documentation (expires after one
year).

d) Subrecipient IACUC/IRB Approvals: Provided official approval is
not specifically required prior to executing the subaward
agreement, the subaward may be issued.

3) After compiling the subaward information, including any revisions, the
ORSP Grants Administrator will forward the paperwork to the ORSP
Subaward Administrator to draft the subaward documentation. The
ORSP Subawards Administrator will share the draft subaward with the
departmental contact for a final review of the dates, amounts/budget, etc.
to ensure accuracy before ORSP transmits the agreement to the
subawardee institution.

4) The ORSP Subaward Administrator will perform a required risk
assessment for each subaward, and if there is a risk concern identified,
the ORSP Subaward Administrator will contact the department/PI to
discuss additional monitoring to help mitigate any potential risk prior to
finalizing the subaward.

Note: MUSC's typical subawardees are universities and are 'low
risk', but when there is a need to mitigate potential risk, it could add
to the time needed to finalize the subaward. Typically, entities that
may not be as research-intensive in their primary business activities
(e.g. local health clinic) will show a higher risk.

5) Any subaward amendments (aka modifications) may require additional
documentation, to be coordinated between Departmental & ORSP
Administrators and given to Subaward Administrators to draft the
amendment(s), then these are reviewed and forwarded to the
subrecipient.

Progress Report/RPPR (MUSC, as the Pass-Through Entity (PTE) is reporting on previous year, and planning for next year)

1) The departments will ensure all of the following documents are completed
and uploaded as one combined file to the Cayuse SP Internal Processing
Form (IPF):

a) Progress report submitted by an authorized institutional official of
the subrecipient

The PHS 2590 'Face Page' is the preferred format for
Progress Reports:

https://grants.nih.gov/grants/funding/2590/2590.htm

b) Itemized/detailed budget and budget justification for the
subrecipient's next budget period

The PHS 2590 'Detailed Budget for Next Budget
Period' & Form Page 6 'Checklist' is the preferred
format:

https://grants.nih.gov/grants/funding/2590/2590.htm

c) Statement of Work (updated as necessary, if changed from
original subaward period)

d) For NIH grants, the Annualized Effort will be required via the PHS
2590 'All Personnel Report':

https://grants.nih.gov/grants/funding/2590/2590.htm

e) Updated Other Support: for all key personnel that lists both
Active & Completed support since either the JIT or previous
year's progress report was submitted

f) Biosketches/Other Support/Human Subjects training for any new
key personnel

g) Re-verify Conflict of Interest Documentation (required annually).

i. External Investigator Listing (external = non-MUSC)

ii. MUSC FCOI information and forms: MUSC FCOI,
MUSC FCOI Forms (on Horseshoe site)

iii. If the subrecipient participates in the FDP FCOI
Clearinghouse, upload a PDF of the certification
to the IPF record.

h) Current IACUC/IRB Approvals

i) Re-verify Human Subjects Training Education (including GCP
training within the last three year if the project is a clinical trial)

j) Current F&A rate agreement or link, IF subrecipient is not part of
the FDP Expanded Clearinghouse

2) When the continuation Award has been received by MUSC, ORSP will
follow the Post-Award process as followed with a new award to prepare
and issue an amendment/modification to an existing subaward, or a new
subaward (depending on MUSC's award requirements).