Proposal Stage -- Roles and Responsibilities
Below is a summary of subaward administration responsibilities and procedures. For full information, please see the BARA Subaward Policies and Procedures Manual.
•Principal Investigators (PIs) are responsible for subrecipient selection, source justification, and technical evaluation.
•Department Chairs, along with the PIs, have accountability for proposal review and line approval as well as the overall proposed expenditures.
•BARA, through the Sponsored Projects Officers (SPOs), has proposal review responsibilities, as well as routing all proposals, with comments, for approval of the Vice Dean for Science and Research.
- Determines the role and scope of work (SOW). If selection is sole or single source, it must be justified by the P.I.
- Determines an overall budget value for subrecipient support which should include an itemization of budget categories, including appropriate salaries, wages, fringe benefits, material, supplies, equipment, travel and other direct cost needed to accomplish the research to be performed. A copy of the subrecipient budget is required in advance of proposal submission.
- Determines all deliverables as proposed in the SOW.
- Determines the reasonableness of costs based on technical requirements.
- Ensures that all the required information is prepared and signed by an authorized official of the organization submitting the proposal. This information includes at a minimum:
- Statement of Work
- Budget and Budget Justification
- Letter of Intent (LOI)
- Rate Agreement
Business and Research Administration (BARA)
The SPO serves as the subrecipient’s administrative contact. In addition to reviewing the required information listed above, the SPO also reviews the subrecipient documents for correctness and completeness, including the following:
•Reviews proposed budget and budget justification that may include a comparison of price quotations submitted, historical information, etc.
•Verifies indirect cost rates (F&A) (if known) and allowability of other cost items. Consults with JHU’s PI on any irregularities discovered in subrecipient proposal.
Negotiation Stage -- Roles and Responsibilities
Business and Research Administration
•Coordinates with Financial Research Compliance office to ensure risk assessment requirements are met.
•Determines appropriate subaward type to be issued
•Determines any special reporting requirements. It may be necessary or desirable to request monthly or quarterly technical or financial reports if required by the sponsor/government or desired by the PI.
•Reviews Subaward Proposal Sheet or Subaward Modification Sheet as submitted by PI/department.
•Ensures that all appropriate known flowdown requirements of the prime award are met.
•Verifies certifications for research involving use of human subjects or vertebrate animals submitted by the collaborating subrecipient organization.
Award/Performance Stage -- Roles and Responsibilities
•PI is responsible for subrecipient performance and compliance, including invoicing requirements.
•PI and Department Head are responsible for monitoring technical effort and financial matters.
•SPO is responsible for contractual aspects of the subaward.
The Principal Investigator/Department is responsible for the following items during the project period, including but not necessarily limited to the following subrecipient activity:
•Monitors the rate of expenditures to determine if costs are being reasonably incurred; if the work is progressing as planned; and if there will be sufficient funds for the duration of the agreement. Approves all expenses charged to the project by the subrecipient. Certifies this information by signing the invoice.
•Monitors all work in progress. This entails maintaining informal contacts between investigators and ensuring compliance with the reporting requirements.
•Determines when a modification is required. A change may require sponsor approval prior to issuing a subcontract modification.
•Determines when SPO assistance is required in attaining compliance from the subrecipient.
Business and Research Administration
BARA’s role is to prepare, negotiate, and execute the subaward agreement. BARA holds final approval rights in the determination of the administrative correctness of the subaward activity that includes the following:
•Determines nature of subaward, selects appropriate type of agreement, and negotiates terms and conditions ensuring that all flowdown requirements are met. Creates the internal JHU purchase order request used to encumber funds on accounts
•Provides administrative guidance and assistance concerning expenditure monitoring to ensure that costs are in accordance with the negotiated budget.
•Reviews and approves all invoices and forwards to the PI for approval.
•Processes approved invoices for payment.
•Creates and issues all subaward modifications.
•Requests and obtains prior sponsor approval for a subrecipient that was neither budgeted nor approved at the proposal stage.
*Whether JHU issues an agreement as a subaward or a contract (such as a purchase order, a contract for personal services, or contract for technical services), the arrangement must be made in the form of a legally binding agreement which contains all the clauses or other provisions and requirements appropriate to either a subaward or a contract and which is signed by an authorized JHU official. The difference between a subawardee and a vendor (paid through a contract) is described in OMB Circular A-133, Section B.210.
Closeout Stage --Roles and Responsibilities
•PI is responsible for information required for various closeout activities.
•Department Head is responsible for supporting the Principal Investigator in gathering all the required final reporting information
•SPO is responsible for ensuring that all final reporting is complete, as well as submission of the Final Patent and/or New Technology Reports.
The PI/Department is responsible for receipt, review, and approval of final closeout documents, including, but not limited to:
•Patent/new technology reports, as required
•Property reports, as required
•Receipt and review of other required closeout documents.
Business and Research Administration
The SPO is responsible for the following items during the project closeout period:
•Submitting the Final Patent/New Technology Report
•Verifying that all final reports have been submitted to appropriate government recipients
•Retaining all required documentation in the contract/grant file for a period of seven (7) years in order to satisfy all audit requirements
•Closeout verification of all subawards.
The administrative responsibilities at various stages in the subaward process are shared by the Principal Investigator/Project Manager (PI/PM), BARA, Purchasing and the Controller’s Office. JHU is ultimately accountable to the prime sponsor for funds management and compliance by subrecipients.
- Immediately after a JHU award is received, the department shall submit a completed and signed Subaward Proposal Sheet to BARA for initiation of the subaward.
- BARA creates a shopping cart in SAP to initiate the creation of the purchase order.
- BARA determines the type of subaward agreement to be issued and prepares the document. This document flows down applicable terms and conditions of the prime award, as well as any supplemental requirements imposed. See subaward manual for details.
- The Controller’s Office annually establishes a risk classification for each subrecipient. For high risk subrecipients, the Controller’s Office will specify any additional required monitoring terms.
- BARA has the final signatory authority for all administrative aspects of the subaward, including but not limited to, rebudgeting approval and modifications.
- Throughout the administration of the award, a complete subaward file of all documentation and correspondence is maintained by BARA.
- Subrecipient submits invoices to BARA for preliminary approval. BARA reviews for:
- funds availability;
- consistency with approved budget;
- period of performance;
- allowability; and
- proper invoice format, including certification signed by authorized official of subrecipient.
- BARA forwards invoice to department. The PI is responsible for reviewing all invoices and the technical progress of work completed by the subrecipient, before payments are authorized.
- For each invoice, the PI is responsible for final approval for payment.
- Once approved/signed by the PI, invoices are returned to BARA for final processing and forwarding to Accounts Payable.
- As part of the monthly reconciliation, the department is responsible for verifying that subrecipients are paid in a timely manner.
- Upon completion of the subaward, all appropriate closing documents are obtained by the PI and/or BARA and forwarded to the sponsor as required. A complete file is retained by BARA according to University policy.