Subaward agreements may be appropriate when MIT Principal Investigators partner with another PI and institution to carry out a portion of a project awarded to MIT.
Subaward Responsibilities
For subawards, MIT is considered a pass-through entity with specific responsibilities detailed in the Uniform Guidance (UG) CFR § 200.331, 200.332, and § 200.333:
- Determine that the relationship meets the definition of a subrecipient and not that of a contractor
- Conduct initial and annual assessments to ensure the subrecipient possesses the financial and administrative infrastructure sufficient to manage federal funds and comply with federal statutes, regulations and terms and conditions
- Verify that every subrecipient is audited as required by § 200.501 when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set in the guidance
- Ensure an appropriate indirect cost rate is being applied
- Monitor the activities of subrecipients to ensure ongoing compliance
Managing the relationship between MIT and the subrecipient entity is a shared responsibility between the PI, the DLCI Admin and the Subaward Team.
Planning for Subawards
Subaward negotiations take time for both MIT and the subrecipient organization. When planning for a subaward:
- Set realistic time frames for subrecipient work to begin
- Do not schedule MIT deliverables that require subrecipient involvement in the early months of the project
- End subaward at least 30 days before project end to ensure sufficient time for award close out
For questions or consultation, please contact subawards@mit.edu.