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Responsibility: KE Contracting Services

Prepared by: Subawards Functional Group

Updated: November 21, 2025

Principal Investigator (PI) responsibilities:

Issuing and monitoring subawards is a joint responsibility lead by the PI. It’s critical for PIs to have regular contact with the subrecipient PI for the following reasons:

  • to ensure that the subaward objectives/scope of work is proceeding as planned and described to the sponsor.
  • to monitor the quality of work being submitted and identify issues that arise in a timely manner.
  • to facilitate review of invoices for reasonableness, allowability and allocability.

Subrecipient PIs are in charge of making programmatic decisions and controlling the method of work at their institution to complete the scope of work outlined in the subaward agreement. Subrecipient PIs are responsible for expending funds and managing the project in accordance with all applicable ASU and prime sponsor requirements. ASU PIs that work closely with their subrecipient PIs have more successful projects as well as help to reduce institutional and project related risk.

Principal investigators are responsible for the following as it relates to the ASU subaward process:

  • Selects subrecipients for inclusion in the proposal
  • Ensures that the scope of work outlines only the work to be done by the subrecipient
  • Verifies that the budget/budget justification supplied by the subrecipient aligns with the scope of work to be performed
  • Provides Research Administrator (RA) with the name and contact information for the individual at the subrecipient institution responsible for assisting with proposal development
  • Assists KE Contracting Services’ Subawards Team with the following:
    • Conducts a review of the subaward agreement for content and accuracy
    • Provides input regarding deliverables and other needs specific to the project
    • Determines the frequency for providing technical reports and maintains documentation for such reports
    • Completes the combined Cost-Price Analysis / Sole Source Justification form for subawards under $100,000
    • Reviews the formal Cost-Price Analysis (completed by subrecipient) for subawards over $100,000
    • Provides Sole Source Justification
    • Notifies KE Contracting Services’ Subawards Team of any known risks in issuing an agreement to the subrecipient
    • Reviews subaward amendments for content and accuracy
  • Monitors progress of the work being performed under the subaward and communicates issues directly to the subrecipient PI and project collaborators
  • Reviews invoices and provides payment authorization verifying the following:
    • Dates match the correct period of performance
    • Charges are reasonable and allowable
    • The charges fall within the subaward budget and statement work
    • Required deliverables have been received (e.g. progress reports, technical reports, etc.)
    • Progress to date is satisfactory
  • Discusses concerns and/or requests additional detail from Subrecipient PI when needed to assist with invoice processing
  • If invoice is unacceptable, notifies the subrecipient and [email protected] of issues
  • Provides [email protected] with written approval to pay and follows up with the subrecipient to:
    • Obtain late/missing invoices
    • Obtain cost sharing documentation, where appropriate
  • Notifies RA and/or [email protected] of concerns including:
    • Failure to make satisfactory progress
    • Late/missing deliverables, technical reports, etc.
    • Inability to obtain documentation from subrecipient for invoices
  • Secures subrecipient cost sharing documentation
  • Notifies [email protected] to initiate subaward closeout at the appropriate time.

RA/Unit responsibilities:

Research Administrators (RAs) often help serve as the first line support for PIs throughout the subaward process. RAs can help the ASU PI in working with other entities by:

  • Ensuring that the PI is aware of the ASU requirements, including the need to seek the other entity’s approval before including their work in the ASU proposal
  • Assessing the potential risk associated with issuing a subaward to other entity.
  • Assisting the PI in preparing what the subrecipient should include in their scope of work
  • Obtaining the contact information for the administrative contact at the other entity
  • Contacting the subrecipient’s administrative contact early to provide guidance on the required documentation needed to initiate a subaward, including upcoming deadlines.

RAs are responsible for the following as it relates to the ASU subaward process:

At proposal time:

  • Contacts subrecipient to seek completion of subrecipient commitment form or letter (as appropriate) with required attachments (e.g. budget, budget justification, SOW), other sponsor required documents, and provides timeline for receipt
  • Responds to subrecipient questions related to the subaward process and required documents for the proposal

During award:

  • Provides missing subrecipient form information to assigned Subaward GCO at the time of project initiation (Subawards cannot be drafted until this information is complete)
  • Works with subrecipient and ASU PI to collect missing subaward documentation.
  • Answers KE Contracting Services’ Subawards Team questions regarding the subaward to be issued or modified
  • Prepares and submits Award Change Request for
    • subawards that were not budgeted in the proposal
    • needed changes to period of performance dates, scope of work, key personnel, budget, and/or other subrecipient changes during the life of the subaward
  • May assist the PI with the review of invoices and may follow up with the subrecipient counterpart for
    • additional detail related to the invoice
    • cost sharing documentation
    • late and/or missing reports and deliverables
  • Provides Grant Manager approval in Workday for subaward invoice payments
  • Advises concerns of PI related to subaward to [email protected]
  • Notifies [email protected] to initiate subaward closeout, when applicable

KE Fiscal Oversight Team responsibilities:

  • Conducts audit, financial, and internal controls risk assessment prior to issuance of a subaward
  • Coordinates annual subrecipient audit compliance reviews

KE Subawards Team responsibilities:

  • Reviews subrecipient commitment form or letter (as appropriate) for completeness – requesting missing info from RA or subrecipient
  • Reviews Award Change Request and accompanying information for modifications (e.g. revised budget, budget justification, scope of work, etc.)- requesting missing information from RA or subrecipient
  • Performs compliance check for items such as:
    • SAM Registration
    • Visual Compliance
    • Audit Review
    • PHS COI
    • FFATA
  • Requests missing subaward documents from subrecipient on behalf of RA as requested
  • Requests sole source justification from ASU PI
  • Submits invitation link for PaymentWorks registration as needed
  • Performs Risk Assessment analysis
  • Drafts subaward agreement or modification and sends to PI for review, input and approval
  • Sends PI approved subaward agreement or modification to subrecipient for review and signature
  • Negotiates subaward terms and conditions with subrecipient, seeking PI input or input from external ASU offices when necessary
  • Distributes fully executed agreement or modification
  • Coordinates annual subrecipient audit compliance reviews
  • Establishes Workday Supplier Contract (SCON) upon completion of subrecipient PaymentWorks registration and resolution of any Workday errors

KE Award Management Team responsibilities:

  • Sets up child account to allow for issuance of subaward either based on award notice or by request of RA/unit
  • Seeks approval from sponsor for changes to scope of work or budget, if required
  • Seeks approval to issue a subaward that was not included in the proposal, where necessary
  • Initiates a KE Contracting Services’ Subawards Team task for subaward set up and modification
  • Manages subaward invoicing process including:
    • Receiving subaward invoices directly from subrecipient at [email protected] or by mail
    • Reviews, processes, and routes invoices for PI approval
    • Sends PI approved invoices to Accounts Payable for processing and payment
    • Addresses accounting and payment issues which arise during the project
  • Manages subaward closeout process including:
    • Receiving notification of subaward closeout from subrecipient, RA, AMT GCO or PI
    • Issues closeout documents to subrecipient for review/completion
    • Processes signed closeout document once returned
    • Reconciles subaward account at closeout: issues final payment, reviews property and inventory reports, and works with the Subawards Team to close out the SCON

Subrecipient responsibilities:

  • Complete the subrecipient commitment form or letter (depending on FDP Expanded Clearinghouse guidelines)
  • Prepare a scope of work (SOW), budget, justification, cost-price analysis (if applicable) and other documents required by the sponsor
  • Prepares revised scope of work, budget, justifications for modifications to the subaward
  • Provide official endorsement on the subrecipient commitment form or letter and other sponsor documents
  • Satisfactorily performs a substantive portion of the project objectives
  • Makes decisions about how to accomplish the objectives of the SOW
  • Maintains compliance with IRB, IACUC, PHS FCOI requirements, and others as required
  • Spends funds in an allowable and reasonable manner
  • Submits invoices and cost sharing documentation to ASU in accordance with the guidelines outlined within the subaward agreement
  • Provides reports/deliverables to the ASU PI as required by the subaward agreement
  • Submits final invoice and completed closeout documents to [email protected].