What is a Subaward?
When MIT Principal Investigators partner with another PI and institution to carry out a portion of a project awarded to MIT, we will issue a subaward agreement to allocate a portion of the work to be carried out at the other institution. In these cases, the subrecipient PI will be responsible for the design, conduct and reporting of the research. The organization must have the appropriate facilities to be able to carry out the work, and the organization's policies and procedures must be sufficient to ensure the responsible use of sponsored funds. This relationship is different than a purchase or service agreement, or a work for hire relationship. Note that this determination has a significant impact on the project budget.
On this page:
The RAS Subawards Team issues and administers subawards in compliance with MIT Policies and Procedures, the applicable sponsor regulations, and the terms and conditions of the prime award, with the ultimate goal of ensuring that the subaward activities satisfy Institute, sponsor and government requirements and protecting the interests of our sponsors and MIT. The Subawards Team is managed by Victoria Grafflin.
- Engagement is determined to be appropriate for a subaward, not a vendor or consultant contract. RAS determines that the scope of work is appropriate for a subaward.
- Subrecipients (subawardees) must qualify as a subrecipient. In order to be considered as a subrecipient in a proposal or subsequent award, the organization must be qualified by the RAS Subawards Team based upon MIT’s Policies and Procedures. A database of current pre-qualified organizations is maintained in Kuali Coeus (see Subawards at Proposal Time). If the organization is not listed in Kuali Coeus, follow the process for requesting a new organization.
- Qualified subrecipients are assigned a risk level. Subrecipients are assigned a risk level by the RAS Subawards Team, based their assessment of the subrecipient's ability to administer the award in a timely manner based on the quality of the internal controls as assessed by an external auditor (e.g. an A-133 audit and/or financial statment audit) and other sources that may provide insights in assessing the risk. The risk level of the subrecipient may impact how the budget and other information is submitted at proposal stage, and may affect the type of subaward agreement that is issued at the award stage. For a more information please see "Evaluating and Managing Subaward Risk".
Subawards have a pre-award and post-award lifecycle, with different considerations and processes at each stage:
The RAS Subawards Team procedures are based on the OMB Circulars as well as FAR regulations such as:
- Uniform Guidance
- White House Office of Management and Budget Circulars
- FAR Subpart 9.1 “Responsible Prospective Contractors”
- FAR 9.104-1 General Standards
- FAR 9.104-3 Application of Standards
- FAR 31 Contract Cost Principles and Procedures
- FAR 42.302 Contract Administration Functions
- OMB Circular Compliance Supplement M; Subrecipient Monitoring
- OMB Circular A-21 - This has been superseded by the Uniform Guidance 2 CFR part 200