Managing Subawards

When managing subawards, PIs and DLCI administrators are generally responsible for monitoring the technical and financial aspects of the subaward relationship, while the RAS Subaward team is responsible for completing annual assessments on the subrecipient organization and issuing modifications.

General

PI/DLCI

RAS Subaward Team
  • Maintain relationship with subrecipient PI and staff throughout the life of the subaward
  • Monitor subaward progress related to meeting project goals
  • Monitor subaward activity and expenses in relation to and alignment with the project scope of work (SOW) and budget
  • Follow subrecipient monitoring plan (if applicable)
  • Alert the RAS Subaward team about any concerns of a programmatic or financial nature
  • Conduct subrecipient initial and annual assessment per federal requirements
  • Draft, negotiate and issue subaward agreement and modifications
  • Assist with close-out process

Invoicing

PI Approval (Technical Progress)

DLCI Financial Officer/Administrator (Compliance)
  • Per MIT policy, PI must review and approve all subaward invoices.  
  • PI checks that costs on invoice are as expected in accordance with the approved subaward budget and project progress
  • PI review and approval constitutes confirmation that appropriate technical progress is being made and that deliverables required under the invoice have been completed and provided. 
  • PI attestation - Sample language: "To the best of my knowledge, I certify that the subawardee's invoice costs appear reasonable and fairly correlate with the technical progress made on this research project."
  • Record of PI approval must be saved for possible future audit

Ensures that:

  • Invoices are reviewed and processed in a timely manner
  • PI reviews and documents their approval based on technical performance
  • Invoice meets compliance criteria
  • PI approval records are available to auditors, when requested
  • Any required cost share is documented on invoices and tracked

Timely processing:

  • Compliant invoices should be paid within 30 days of the invoice date
  • Note issues that delay invoice payment

Compliant invoices must include (download sample and checklist [DOCX]):

  • Allowable costs that align with approved subaward budget
  • Proper Subaward ID#, Purchase Order #, unique Invoice Identification #
  • Invoice submission date and date range covered by invoice
  • Signature, printed name, and title of authorized signatory (cannot be signed by subrecipient PI)
  • Required attestation language (2 CFR 200.415 for federal – similar allowed for non-federal)
  • Final Invoice must be marked “Final”

Approval and Questions:

  • Reject invoices that do not meet compliance criteria. Explain rejection to subrecipient for correction and resubmission
  • Work with B2P (B2P@mit.edu) on issues such as:
    • Expired cost object
    • Indirect costs not charging correctly
    • Cannot modify PO – requisitioner name needs to be updated
  • Alert the RAS Subaward team (subawards@mit.edu) about issues with technical progress, subrecipient performance, or late invoices that may prevent payment
  • Approve in B2P (COUPA) after PI approves and if invoice meets compliance criteria 

Modifications

PI/DLCI

RAS Subaward Team
  • Submit B2P Change Order request (Quick Card [PDF]) to issue a subaward amendment to:
    • Extend the period of performance (POP) end date
    • Increase/decrease funding
    • Revise SOW/budget
    • Other changes (e.g., new PI)
  • Provide detailed modification instructions
    • Upload Subaward Modification Checklist [PDF] that includes all information needed to issue accurate amendment
    • Attach any updated documentation (e.g., revised budget, compliance approvals, etc.) to purchase order (PO)
    • Incomplete/unclear instructions may delay amendment issuance
  • Contact B2P@mit.edu for questions regarding PO errors or issues
  • Draft and issue subaward amendments
  • Obtain clarifications from DLCI if needed
  • Ensure entity assessment is up to date
  • Copy PI and DLCI admin when sending fully-executed modification to subrecipient

Close-out

MIT will not close out a prime award until all subawards issued under the prime award have been closed out. Subawards will only be considered formally closed when all applicable closeout requirements have been accomplished.

PI/DLCI

RAS Subaward Team
  • Proactively engage subrecipient toward POP end date
    • To collect final deliverables and reports as applicable
    • Remind subrecipient to submit final invoice (marked as "FINAL")
    • Confirm final invoice has been submitted for payment
  • Submit Closeout Request form [PDF] to RAS Subaward team (subawards-closeout@mit.edu)
    • Confirm reporting requirements have been met
    • Confirm balance to be de-obligated
  • Confirm receipt of complete and accurate Closeout Request Form
  • Collect/confirm receipt of final patent, property, or other report from subrecipient (as required)
  • Soft close B2P PO
  • Change KC subaward record statuses – Ended, Financially Closed, Closed