Overview

The following sections outline the process for requesting and executing a new subaward agreement, amending an existing subaward agreement, requesting subaward pre-award spending, and monitoring subawards through Research and Sponsored Programs. If you have questions or need more information, please contact our Subaward Team at subawards@research.rutgers.edu. Please refer to the Rutgers Subrecipient Issuance and Modification policy for further guidance and details.

Executing New Subawards

Note: A subaward should never be issued to an individual. Please see Subaward Preparation for other important subaward information including preparing proposal documents and distinguishing between subawards vs. service contracts.

1. Upon activation of a RAPSS AWD record which includes subrecipients, an automatic RAPSS email is sent to the RSP Subaward Team email to initiate the necessary subaward agreements.
2. The assigned RSP Subaward Specialist will initiate the respective RAPSS SUBAWARD record and utilize the initial documents provided at the proposal submission stage to initiate the subaward process, if no changes are requested by the department. Please see Subaward Preparation for more information.
3. If needed, the Principal Investigator and/or Department Administrator must submit any revised subrecipient documents to the RSP Subaward Specialist:
   • Subaward Commitment Form: Including institutional contact information and any compliance documents (such as IRB/IACUC).
   • Budget and Budget Justification: Including the subrecipient’s direct and indirect costs, calculated using the subrecipient’s approved facilities and administrative (F&A) and fringe benefit rates, and any committed cost sharing.
   • Scope of Work: Including a clear description of the work to be performed, the proposed timelines and deliverables, and other information such as bio sketches of subrecipient key personnel if necessary.
   • Compliance Protocols/Information: Including approval letters for IRB, IACUC, Biosafety, etc.
   • It is the responsibility of the PI / Department Administrator to ensure that the Subrecipient is registered as a Vendor / Supplier in Marketplace, the Rutgers supplier Portal, by the time all subaward documentation has been provided to the RSP Subaward Team.  Please visit Cornerstone-Supplier Portal for information and instructions on how new Suppliers / Vendors can be added.  RSP will not be able to create the subaward’s requisition and associated purchase order until the Subrecipient’s registration has been completed. Please reach out to Procurement Services for any additional questions you may have or assistance you may need.
   • Subaward Project String Form: The PI or Approver must be activated in Marketplace in order to be able to approve subrecipient invoices. Please reach out to Procurement Services for any additional questions you may have or assistance you may need.
4. The RSP Subaward Specialist will review the subrecipient documents against the Prime Award file, verifying consistency and denoting any special clauses, flow-down, or unusual requirements.
5. The RSP Subaward Specialist will complete an internal subrecipient risk assessment and will prepare the subaward agreement using the appropriate template for execution.
6. The RSP Subaward Specialist will negotiate terms and conditions with the subrecipient and receive a partially executed subaward agreement.
7. The Research and Sponsored Programs / Research Contract Services Director/ Associate Director will approve and fully execute the subaward agreement. Subaward agreements cannot be fully executed until the Project ID number is established for the associated Rutgers award.
8. The RSP Subaward Specialist will create the purchase order. Please be sure to provide the following information by completing the Project String form:
   • Project Number
   • Expenditure Type
   • Unit-Division-Organization (UDO) code
   • Location code
   • Business Line
9. The RSP Subaward Specialist will distribute the fully executed subaward agreement to the Subrecipient, Rutgers PI/Department and will activate the RAPSS SUB record.

Please note: upon collection of all required subaward documentation, it may take up to 20 business days for a subaward agreement to be developed and sent to Subrecipient for review and signature.

Amending Existing Subawards

As research relationships and projects evolve, changes may need to be reflected in the existing subaward. Common reasons for amending a subaward to include, amongst other, providing additional or incremental funding, extending the period of performance, changing the Rutgers or the Subrecipient PI, or modifying the reporting schedule. It is important to note that some changes, such as scope of work changes, change in the Subrecipient principal investigator or transferring the subaward from one recipient to another, may require the prior approval of the prime sponsor.

If a subaward modification is required, a Subaward Modification Checklist must becompleted and signed by the Principal Investigator (PI) and forwarded to subawards@research.rutgers.edu along with the following documents:

• Subrecipient’s Scope of Work for next increment, if necessary
• Subrecipient’s Budget and Budget Justification for next increment, if necessary
• Subrecipient’s IRB/IACUC or other compliance approval documents, if necessary
• Attachment 3B-2 for updated subrecipient contact information
• Completed Project String

Subaward Pre-Award Spending

When Rutgers is the Prime institution, the sponsor may give notice of a pending award, but receipt of the official award notice may be delayed. In such cases, an Intent to Subcontract Letter can be issued to the Subaward institution so that the collaborating institution can begin work. This option would pertain to:

• New awards under pre-award spending
• Continuation years on an existing award

It is important to note that just as Rutgers assumes liability for its spending prior to receipt of the actual award notice, the liability for any expenditures of the Subaward institution is assumed by said institution for any expenditures prior to issuance of a fully executed subcontract. The Intent to Subcontract Letter is prepared by the department and then signed and submitted by Research and Sponsored Programs.

NIH Final Updated Policy Guidance for Subaward/Consortium Written Agreements

Effective January 1, 2024 and pursuant to NOT-OD-23-182, the National Institutes of Health (NIH) requires international subrecipients to provide access to copies of all lab notebooks, all data, and all documentation that support the research outcomes as described in the progress report to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report (RPPR) submission.  Such access may be entirely electronic.

This requirement is applicable to all new NIH subawards, as well as any currently active NIH subaward modifications.  As such, the NIH subaward agreement and subaward modification templates issued to foreign subrecipients have been revised to include the following language:

“Pursuant to NIH Notice NOT-OD-23-182 issued on 09/15/2023, the Subawardee agrees to provide access to all lab notebooks, all data and all documentation that supports the research outcomes as described in the Subawardee’s technical progress reports, to the Rutgers Project Director / Principal Investigator and his/her designee with a frequency of no less than once a year, in alignment with the timing requirements for the report submission.  Such access may be entirely electronic”.

The Subrecipient Commitment Form has been updated to include reference to this requirement.  Please ensure to use this for all new subawards to be included in outgoing proposals and that the appropriate box has been selected by the future subrecipient acknowledging that the referenced term must be accepted if proposal is awarded and subaward agreement is issued.

Additional information regarding this NIH notice can be found at the Revised Subaward NIH Webpage and the new Frequently Questions on Foreign Subawards.

If you have any questions, or need further information, please do not hesitate to reach out to subawards@research.rutgers.edu .

Subaward Monitoring

Once a subaward agreement is issued, the Principal Investigator is responsible for monitoring subrecipient costs and performance. Please download the Subrecipient Monitoring Policy for more information. The Subaward Monitoring Department Checklist is also available to help guide review of subrecipient invoices and progress towards programmatic goals.

Please refer to the Subaward Invoice Approval Process for guidance on how invoices must be reviewed and approved in Marketplace.