Faculty who apply for funding with colleagues at other institutions will usually have to choose whether to submit the proposal through Wellesley or through their collaborator's institution. Ordinarily, the institution where the majority of the project will take place will be the lead. The two most common scenarios are described below. Any faculty member planning to prepare a proposal with a colleague at another institution should consult with the Office of Sponsored Research as early as possible.
If Wellesley College is the lead institution, the other PI's expenses may be included in the proposal as a subcontract to the co-PI's home institution. At minimum, the co-PI's institution will need to provide a statement of work, a budget and budget justification, and a completed Subrecipient Commitment Form.
Subrecipient award, monitoring, and closeout process
Determine if a subrecipient will be involved in your project
Using the Subaward Decision Tree, and in consultation with the Director of Sponsored Research or WCW Director of Grant & Contract Services (pre-award), or the Associate Controller or the WCW Grants Accounting Manager (post-award), determine if your project includes a subrecipient or a contractor/vendor. Please refer to the Wellesley College Purchasing Policy when considering a contractor or vendor post-award.
Collect Subrecipient Commitment
When a subrecipient has been identified, the Subrecipient's institution will need to provide a statement of work, a budget and budget justification, and a completed Subrecipient Commitment Form in advance of proposal submission. Other proposal documents required by the sponsor could include biosketches from key personnel, facilities and other resources statements, or audited financial statements.
Review Subrecipient proposal
As part of the proposal approval process, the Office of Sponsored Research (or for WCW, Grant & Contract Services) reviews the subrecipient proposal package for accuracy, compliance with sponsor regulations and College policies, debarment or suspension of the subrecipient, and the capacity of the organization to meet subrecipient requirements.
Issue Subaward Agreement
Upon receipt of a prime award, the risk associated with potential subrecipient entities will be evaluated using a Risk Assessment Questionnaire (a standard tool published by FDP) or other suitable means. Factors impacting risk include subrecipient’s experience with Federal/non-Federal grants, frequency of audits and any audit findings, and the scope and location of work to be performed by the Subrecipient. When necessary, the PI will be informed of a high risk subrecipient. The feasibility of a subaward and/or any necessary management steps will be discussed.
With a satisfactory risk assessment/management plan in place, the Office of Sponsored Research (or the WCW, Grant & Contract Services) will draft a subaward agreement. This process is undertaken in coordination with the PI. Subaward Agreements will flowdown all applicable provisions of the prime award to the subrecipient. Foreign subrecipients may require clauses such as export controls, governing law, and currency. For high risk subrecipients, additional terms may be included, such as requiring back up documentation for expenses or more frequent reporting or invoicing. A monitoring plan for high risk subrecipients may also include site visits and/or desk reviews.
Monitor Subrecipient Performance
The Principal Investigator is responsible for monitoring subrecipient’s technical and programmatic activities through regular communication with the subrecipient PI, review of performance reports as required, and approval of subrecipient invoices. The College's Post Award Services (PAS) will review subrecipient expenditures to ensure the charges are allowable, allocable, reasonable, and that the charges are within the period of performance. PAS conducts an annual review of subrecipient Federal audit reports to verify that the subrecipient has completed a Federal audit and to assess the audit findings and corrective action plan, if any. PAS reports eligible subaward agreements in the Federal Funding Accountability and Transparency Act (FFATA) Reporting System.
Closeout Subaward Agreement
A final invoice (marked final) is generally expected within 45 days of the end date of the subaward agreement. PI approval of the final invoice certifies that the programmatic milestones were met, and all required final technical, financial, and administrative reports have been received. Charges incurred outside of the dates of the subaward or charges that are received after the final invoice will not be reimbursed.
If the other PI's institution is the lead, the Wellesley PI will usually have to prepare the documentation described above for submission to the other PI’s institution.