Sponsored Project Subawards

Effective Date: April 1, 2008

Policy Statement

As the recipient of an award for a sponsored research project (a "Sponsored Project"), Columbia University (the "University") may award financial assistance to a collaborator (a "Subrecipient") to facilitate performance of and payment for specific work to be conducted by such Subrecipient in connection with the Sponsored Project (a "Subaward").  As a condition to its acceptance of funding from a sponsor, the University is obligated in its role as recipient of the primary award to undertake certain stewardship activities and to ensure compliance by the Subrecipient with federal, state and local laws and regulations and with the restrictions placed upon the primary award by the sponsor.  When the University assigns responsibility for conducting a portion of the work under the primary award to a Subrecipient, the University remains responsible to the sponsor for managing funds and meeting performance goals.  This responsibility involves both pre-award assessment of the proposed Subaward and Subrecipient and post-award monitoring of the programmatic and financial activities of the Subrecipient under the Subaward.

This Policy applies to all Subawards issued in connection with Sponsored Projects undertaken by investigators at the University regardless of the primary source of funding.

Reasons for the Policy

This Policy seeks to:

• ensure that risks associated with a Subaward or a Subrecipient are identified and managed prior to the grant of a Subaward;
• promote compliance with federal, state and local laws relating to Subrecipient monitoring;
• assign appropriate unit-level and individual responsibility and accountability for the establishment and management of Subawards; and
• ensure that a sponsor's funds are appropriately spent and that the University and its sponsors receive value for funds expended.

Primary Guidance to Which This Policy Responds

This Policy primarily responds to the following regulations of the federal Office of Management and Budget ("OMB"):

• OMB Circular A-110 (http://www.whitehouse.gov/omb/circulars/a110/a110.html)
• OMB Circular A-133 (http://www.whitehouse.gov/omb/circulars/a133/a133.html) ("A-133")
• 31 USC 7502(f)(2)(B) (Single Audit Act Amendments of 1996) (http://www.ignet.gov/single/saamend.html#7502)

Responsible University Offices and Officers

Office of Research Administration
Associate Vice President for Research Administration

Clinical Trials Office
Executive Director

Office of the Controller
Executive Director, Restricted Funds

Revision History

This Policy supersedes the Policy on the Establishment of Sponsored Project Subawards.

Who is Governed by this Policy

Faculty and staff who are responsible for authorizing, processing and monitoring Sponsored Project Subawards.

Who Should Know this Policy

1. All persons governed by this Policy [see above]
2. Principal Investigators
3. Departmental Administrators and other departmental staff
4. Deans and Department Chairs
5. Office of Research Administration
6. Clinical Trials Office
7. Office of the Controller

Exclusions and Special Situations

Not applicable

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