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Sponsored project awards made to The Johns Hopkins University (JHU) are
generally conducted within the physical boundaries of JHU by faculty and staff.
However, a portion of the work may need to be provided outside JHU by a third
party. The third party (subawardee) is responsible for a clearly defined
portion of the project, providing the leadership and direction of a responsible
project director and the resources necessary to conduct that portion of the work
assigned to them and to assist in designing the project. Costs associated with
this work may include personnel costs, supplies, equipment, travel, overhead, etc.
Such an arrangement is carried out by the issuance of a subaward.
It is the policy of JHU that, in issuing and administering subawards, JHU and the
subrecipient are in compliance with the following:
- JHU Accounting Policies and Procedures as well as the policies and
procedures that are mandated by the government and implemented by the University
- The applicable sponsor terms and conditions
NOTE: The ultimate goal is to guarantee that the subaward activities satisfy
JHU and governmental audits and reviews while also protecting the research program’s
best interests. Therefore, all subawards must be issued and signed by the Divisional
Research Administration Office.
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General Roles and Responsibilities
- Principal Investigators are responsible for subawardee
selection, source justification, and technical evaluation.
- Department Heads are responsible for supporting the Principal Investigator in
proposal preparation.
- Department Chairs, along with the P.I.s, have accountability for proposal
review and line approval as well as the overall proposed expenditures.
- Division Research Administration Office has proposal review responsibilities,
as well as preparing all proposals, with comments, for the Vice Dean of Research’s
signature.
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- Principal Investigator/Department
Holds selection and final approval of all components of the subaward.
This includes the following:
- Determines the role and sets the scope of work for the
subawardee(s). If selection is sole or single source, must be
justified by the P.I.
- Determines an overall budget value for subaward 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 subawardee budget is required in
advance of proposal submission.
NOTE: NIH has modified its policy on how the Facilities and
Administrative costs for subawards are calculated. Instead of being
included as part of JHU's direct costs, the F&A for subawards will now
be calculated separately. This change of policy is found at the
following website:
http://grants.nih.gov/grants/guide/notice-files/NOT-OD-05-004.html
- 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 P.I.
- Determines nature and timing of all deliverables as proposed in
the SOW.
- Determines if proposed costs are reasonable based on technical
requirements.
- Ensures that all the required information is prepared by the
subawardee and attached to the proposal for submission to BARA for
review and signature. (See
Subcontract Award and
Subcontract Modification
Form).
- Ensures that all subawardee proposal information is signed by an
authorized official of the Company submitting the proposal.
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- Businesses and Research Administration(BARA)
The SPO reviews the subaward documents to determine correctness and completeness,
including at least the following:
- Checks justification for subawardee selection. If competitive,
includes documentation in the file. If single or sole source, assures
that the appropriate reasons for selection are documented to the file.
- Reviews Principal Investigator’s price analysis that may include a
comparison of price quotations submitted, historical information, etc.
- Reviews the budget for verification of indirect rates (if known)
and checks the need for foreign travel, equipment purchases, etc.
- Consults with the PI on any irregularities discovered in subawardee
proposal.
- Ensures that all appropriate known flowdown requirements of the
RFP or the grant applications guidelines are met.
- Verifies certifications for research involving use of human
subjects or vertebrate animals submitted by the collaborating subrecipient
organization
- SPO serves as the subrecipient’s first point of contact pertaining
to all contractual issues
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Roles and Responsibilities
- Principal Investigators are responsible for subawardee
technical effort and cost experience.
- Department Heads are responsible for supporting the Principal Investigator in
monitoring technical effort and financially related matters.
- Sponsored Projects Officer is responsible for legal aspects of the
subaward as well as assistance in monitoring.
- Principal Investigator/Department
Is responsible for the following items during the project period, including
but not necessarily limited to the following subawardee 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 subawardee.
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. If the Principal Investigator needs assistance in attaining
compliance from the subcontractor, Research Administration is informed and is
prepared to assist resolving the issue(s).
- Determines if a proposed modification will involve a significant
change in scope of work or objectives. Such a change may require sponsor
approval prior to issuing a subcontract modification.
- Prepares and/or secures certain closeout documents, i.e. patent
report, equipment report.
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- Business and Research Administration (BARA)
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 performance, that include the following:
- Determines nature of subaward selects appropriate type of vehicle
and negotiates terms and conditions ensuring that all flowdown requirements
are met.
- Obtains prior sponsor approval for subaward if necessary.
- Creates the internal JHU purchase order used to encumber funds on accounts
- Assists in monitoring reporting requirements of the subaward.
- Provides administrative guidance and assistance concerning expenditure
monitoring to ensure that costs are in accordance with the negotiated budget.
- Approves invoices in selected cases.
- Creates and Issues all subaward modifications.
- Ensures that all closeout documentation is in the file and that file
is marked for retention period.
*Whether JHU issues an agreement as a subaward or a procurement
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 procurement
contract and which is signed by an authorized JHU official.
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The administrative responsibilities at various stages in the subaward process are
shared by the Principal Investigator/Project Manager (PI/PM), the Divisional Sponsored
Projects Office, Purchasing and the Controller’s Office.
- The subrecipient's proposal should normally be sent to JHU’s PI, who
incorporates it into his or her proposal before forwarding to the sponsored
projects office, where it is examined for form, policy adherence, sufficient
information and correct detail.
- Immediately after a JHU award, the PI shall contact the JHU Research
Administration Office for initiation of subaward activity.
- If required under FAR Clause 52.219-9 for federally funded subcontracts
exceeding $500,000, the Research Administration Office will obtain a Small
Business Subcontracting Plan from the subcontractor.
- During the time the JHU award is being negotiated and accepted, the
subaward is being prepared by the Research Administration Office.
- The Research Administration Office prepares a purchase requisition
ensuring that the funds are shown on the budget as a legally obligated encumbrance.
- Throughout the administration of the award, a complete subaward file
of all documentation and correspondence is maintained in the Research Administration
Office.
- Subrecipient invoices are managed according to divisional policy and
procedure. In all cases, the PI is responsible for final payment approval
and for ensuring payment is promptly remitted by the JHU Office of the Controller,
Accounts Payable Department
- The Research Administration Office has the final signatory authority for
all administrative aspects of the subaward, including rebudgeting approval and
modifications.
- Upon completion of the subaward, all appropriate closing documents are
obtained by the PI and the Research Administration Office and forwarded to the
sponsor.
- A complete file is retained by the Research Administration Office for a
predetermined period of time to satisfy all audit requirements.
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Individual circumstances generally dictate the subaward contractual
arrangements. Depending upon the type of Prime Agreement and the type of subawardee
institution (Profit, Not for Profit, Educational, State, etc) the Research Administrator
will select an appropriate type of vehicle. The following is a list of the possible types
of subawards:
- Cost Reimbursement. This type of subaward provides for payment of allowable
incurred costs, to the extent permitted in the prime award. These subaward agreements
establish an estimate of total costs for the purpose of obligating funds and
establishing a ceiling that the subrecipient may not exceed.
- Cost Reimbursement-No Fee Contract. This type of subaward is a
cost-reimbursement agreement in which the subrecipient receives no fees.
- Cost Plus Fixed Fee. This type of subaward is a cost reimbursement contract
that provides for payment to the subrecipient of a negotiated fee that is fixed at the
inception of the agreement. The fixed fee does not vary with actual costs, but may be
adjusted as a result of changes in the work to be performed.
- Fixed Price
- Firm Fixed Price. This type of subaward provides for a price that
is not subject to any cost adjustment on the basis of the subcontractor’s
experience in performing the contract. This type of subcontract provides
for the maximum incentive for the subcontractor to control costs and perform
the work plan in the most effective manner.
- Fixed Price Subject to Adjustment. This type of subaward contains a
contingency clause included in the agreement that provides for an upward or
downward revision to the total costs.
- Time and Materials. This type of subaward provides for the acquisition of
supplies or services on the basis of direct labor hours at specified hourly rates,
including wages, overhead, and general and administrative expenses, and if required,
the provision of materials with a negotiated handling fee.
- Labor Hour. This type of subaward is similar to a time and materials type
of subcontract, differing only in that the subcontractor does not supply materials.
- Independent Contractor. Used for an individual or non-corporate business
entity that provides personal services to the University while retaining control over
the means and methods of accomplishing the result. Typically, the independent
contractor will have a principal place of business other than at the University, offer
services to the general public and will have Clients other than the University. If an
individual does not clearly meet the IRS guidelines for an independent contractor, that
individual must be paid through the payroll system as a University employee.
Independent Contractor Certification & Agreement
NOTE: JHU generally issues cost reimbursement awards to educational institutions,
hospitals and other non-profits entities
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Payment Provisions
- Advance payment. This type may be considered
useful and appropriate in subawards for experimental, research, or development
work with small businesses and foreign institutions. Generally, advance payments
provide the start up funds for the operational expenses related to a program
- Scheduled payment. In some instances, a Sponsor
will include a payment schedule with the award. This schedule will outline the
expected automatic payments according to the project period and award amount.
- Milestone payment. This type of payment is
based on the project deliverables being completed and forwarded to the Sponsor on
pre-established dates. At these given points, milestone payments will be issued to
the institution.
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Flowdown Considerations
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- The Research Administration Office reviews the subaward to ensure that
all necessary closing actions have been carried out, including receipt of
all appropriate closing documents.
- The following reports are required for closeout within 30 – 45 days
of termination:
- Final technical report –submitted directly to PI and copy
to Research Administration Office
- Final equipment report, if required, copy to be obtained by
Research Administration Office
- Final patent report to be obtained by Research Administration
Office
- Final voucher and all appropriate releases – to be obtained by
Research Administration Office
- The PI is responsible for seeing that an acceptable final report is
received from the subrecipient.
- The final invoice is forwarded to the PI, who is responsible for the
review and authorization of the final payment to the subrecipient.
- A complete file is retained by the Research Administration Office
for a predetermined period of time to satisfy all audit requirements.
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