Managing Subawards

• 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 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

• 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 Sub 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 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 

• Submit B2P Change Order request (Quick Card) 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 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

• 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 to Subaward Team
  • 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