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Owner: Vice President for College Advancement
Author: Director of Foundation and Government Resources
Contact information: Amanda Abrahamson Roseth
Effective Date: January 10, 2024
I. Purpose
This policy ensures that The College of St. Scholastica (CSS) will comply with the provisions of the Federal Office of Management and Budget’s regulations, including Uniform Guidance (2 CFR 200). It provides direction to faculty and staff for the proposal and administration of subawards.
II. Definitions
- Project Director / Principal Investigator – The CSS faculty or staff member responsible for administering a grant project.
- Pass-through entity – The non-federal entity, in this case CSS, that provides a subaward to a subrecipient to carry out part of a Federal program.
- Prime Award – A grant made by a Federal Agency directly to CSS.
- Subaward – An award provided by CSS, the pass-through entity, to a third party, known as a subrecipient, for the purpose of carrying out part of the Federal program for which the pass-through entity (CSS) received the Prime Award.
- Subrecipient – A non-federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program.
III. Policy
As the primary recipient of a Federal award, The College of St. Scholastica is responsible for ensuring that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Therefore, the College will assess potential subrecipient relationships and monitor ongoing subrecipient activities to provide reasonable assurance that subrecipients are in compliance.
The College will follow the requirements found in Uniform Guidance to distinguish subaward relationships from contract relationships. This determination will be made at the proposal development stage, based on the relationship's substance. If a potential subaward/contractor distinction was not possible prior to proposal submission, a determination will be made after submission based on a statement of work and will be subject to agency approval.
Subawards will be developed, made, and administered according to The College of St. Scholastica Federal Grant Subaward Procedure and based on a risk assessment of the proposed subrecipient. The Principal Investigator/Project Director (PI/PD) is ultimately responsible for the management and administration of the subaward in accordance with Uniform Guidance.
IV. Individuals and entities affected by this policy
- Foundation and Government Resources
- Finance
- Grant Project Directors / Principal Investigators
- Pass-through entities
V. Related documents, forms, and procedures
Subaward Procedure
The College reserves the right to modify policies at any time, ensuring the involvement of relevant committees and constituents in the decision-making process (e.g., policy committee, faculty assembly, staff council, student government association, etc.)