Principal Investigators (PIs) negotiate subawards with subrecipients through the Office of the Research Administration. When a subaward agreement is fully executed, it must be submitted in the electronic requisitioning system and routed to the Office of Sponsored Programs Accounting for approval. Once all approvals are obtained, a purchase order is created in PeopleSoft. The account number(s) on the requisition/purchase order should correspond with the budget that was entered into the appropriate grant, using the range of accounts (5151-5164) set aside for subcontracts.
Helpful Hint: when an “Under $25K” and “Over $25K” account are used, the requisition should contain two ‘items’ rather than a split. This will ensure that A/P uses the first $25,000 of the PO from the “Under $25K” to pay invoices, before using the funds in the “Over $25K” line.
When invoices are received from subawardees, they are pre-checked by SPA and sent to the PI/Department for review and signature. By signing the invoice, the PI is indicating that the costs are reasonable, allowable, allocable, reflect the work performed and are in accordance with the terms of the subaward agreement. If the PI chooses to have a designate sign the invoices, the individual must have first-hand knowledge of the project in order to judge the quantity and quality of the work represented on the invoices. Once the PI or his/her designate signs, the invoice should be returned to the appropriate SPA Specialist. S/he approves the invoice and forwards it to Accounts Payable for payment under the assigned purchase order number.
Any issues regarding subrecipient performance should be reported to the Office of the Vice Provost and SPA as soon as possible.
SPA is responsible for ensuring that all of Tufts’ subrecipients are in compliance with OMB Circular A-133 requirements. Beginning in December each year, SPA sends correspondence to all subrecipients to request documentation confirming their compliance with A-133 requirements. Since payments to subrecipients are segregated into a specific range of accounts, a PeopleSoft query is run to identify payments made during the preceding fiscal year. Using this list, a questionnaire is sent to the subrecipients to ascertain if the A-133 audit has been completed and whether or not there were any findings. Any subrecipients that indicate findings on their A-133 report are required to submit a copy of that report. If a response is not received, in mid-February a second request is sent. In May follow-up phone calls and e-mails are sent to the remaining subrecipients who have not responded or responded that their audit would be completed at a later date. When no response is received by June 1, the PI will be contacted for assistance and invoices will be held until the requested information is received. A log for each subrecipient is maintained to track the status of subreceipient responses.
Assessment of Subrecipient Risk
Since subrecipients are often organizations that participate in federal research themselves, many are required to complete their own A-133 audits. Therefore, they must ensure that they have adequate controls and systems as established by their respective institution to monitor grant expenditures. For those subrecipients not required to complete an A-133 audit, SPA conduct a risk assessment based on prior history and may request additional information (i.e. financial reports) or may run a Dun & Bradstreet credit report to aid in the assessment. (A DUNS number is required for all federal subrecipients prior to the execution of a subaward.) In addition, PIs are responsible for evaluating the quality of the work performed by subrecipients and ensuring that contractual agreements are met. Finally, in order to ensure A-133 compliance SPA may request other information (annual reports, source documents, etc.) and/or may conduct site visits. Tufts’ risk assessment process is being reviewed in the Office of Research Administration and a link to their website will be provided here when it is finalized.
In the Purchasing Office, vendors are required to certify that when they are awarded with and accept a Tufts purchase order they are not a debarred or disqualified supplier. This certification is necessary for any vendor paid from federal grant/contract funds.