Office of Research and Sponsored Programs

Subawards

What is a Subaward?

A subaward is a legally binding agreement issued by Middle Tennessee State University (MTSU) to another institution or organization to carry out a portion of the scope of work on an externally sponsored project. Subawards are issued when MTSU is the prime recipient of an award, and another entity will perform a substantive part of the project.

Subawards are governed by federal regulations under 2 CFR 200, which outline requirements for subawards, subrecipient monitoring, accountability, and compliance.

Subrecipient vs. Contractor/Vendor

Before including a collaborator in a proposal, it is important to determine whether they should be classified as a subrecipient or a contractor/vendor.

Subrecipient

Participates programmatically in the project.
Has programmatic decision-making authority.
Shares responsibility for achieving project goals and deliverables.
Is subject to sponsor and federal compliance requirements.

Contractor/Vendor

Provides goods or services within normal business operations.
Does not participate in programmatic decision-making.
Provides deliverables or services for the benefit of the project but is not responsible for project outcomes.
Is subject to procurement terms, not subrecipient monitoring requirements.

If you’re unsure how to classify a collaborator, please complete the Subrecipient or Contractor Classification checklist to help make the determination. If you’re still unsure after completing the checklist, contact the Subawards Team for guidance.

Planning and Proposal Preparation

When a proposal includes a subrecipient, the Principal Investigator (PI) must identify subrecipients early and coordinate with the Subawards Team to ensure all required documentation is collected in time for proposal submission. Early communication helps prevent delays and ensures a smooth contracting process if the proposal is funded.

Timeline for Proposals with Subawards

To ensure timely submission and compliance with university and sponsor requirements, the following timeline applies to all proposals that include subawards.

30 Days Prior to Proposal Due Date
MTSU Principal Investigators (PIs) are required to communicate their intent to submit a proposal by completing the Cayuse Proposal Request Form at least 30 days before the sponsor’s due date. When completing this form, PIs must indicate whether the proposed project includes any subrecipients by answering “Yes” to the question: Does the proposed project include any subrecipient(s)/subaward(s)? Selecting “Yes” automatically notifies the Subawards Team, allowing them to begin coordinating with the subrecipient and collecting the required documentation.

14 Days Prior to Proposal Due Date
Finalized subrecipient documentation — including all required forms, signatures, and supporting materials — must be submitted to the Subawards Team no later than two weeks before the proposal due date. This allows sufficient time for review and any necessary adjustments to the MTSU proposal package.

7 Days Prior to Proposal Due Date
The final MTSU proposal documents must be submitted to ORSP, and the Full Proposal in Cayuse must be routed for internal approvals at least one week before the sponsor’s due date. Early communication with the Subawards Team ensures that all subrecipient documentation is received and reviewed in time to meet internal and sponsor deadlines, minimizing delays and supporting a smooth submission process.

Subrecipient Documents

For each incoming subaward, several documents are required — and others may be requested as supplemental — before a subrecipient can be included in a proposal with MTSU. It is important to note that only the Subawards Team may contact subrecipients to request the required documentation. This helps maintain clear communication and ensures all materials are collected and reviewed in compliance with university and sponsor requirements. All subrecipient documentation should be submitted directly to the Subawards Team for review and processing.

Required Subrecipient Documents

Subrecipient Information Form
The Subrecipient Information Form gathers key organizational and administrative details from the subrecipient, including compliance certifications, contact information, and organizational status. The information provided is used to complete the subrecipient risk assessment and populate key sections of the subaward agreement.

Scope of Work (SOW)
The scope of work outlines the specific tasks, deliverables, and responsibilities the subrecipient will perform under the project. This document will be incorporated directly into the subaward agreement and is required by the sponsor at the proposal stage.

Budget and Budget Justification
The budget and budget justification provide a detailed breakdown of the project costs, and an explanation of how the funds will be used. This information is reviewed to ensure costs are appropriate, allocable, and allowable under sponsor and federal regulations. It is also included in the subaward agreement to define financial expectations and is required by the sponsor at the proposal stage.

Title VI and Title IX Compliance Forms
These required documents include the Title VI and Title IX Survey and the Assurance of Title VI Compliance Form. These forms are required by the State of Tennessee to ensure both MTSU and its subrecipients comply with state and federal civil rights laws.
- Under Tenn. Code § 4-21-203, the Tennessee Human Rights Commission is charged with verifying that all state government entities—and by extension their subrecipients—comply with Title VI of the Civil Rights Act of 1964. In addition, Tenn. Code § 4-4-123 requires state agencies to ensure compliance with all applicable federal nondiscrimination laws, including Title IX of the Education Amendments of 1972.
- Because MTSU is a state entity, its subrecipients are also subject to these state compliance requirements. The completion of these forms allows MTSU to collect the data necessary to meet the reporting and verification obligations outlined in Tennessee law.
W-9 Form
The W-9 form provides the subrecipient’s taxpayer identification number and legal name. This must be a current, signed copy. This information is required for vendor setup and payment processing in MTSU’s financial system.

Most Recent Audit Report
The most recent single audit or financial statement audit is used to evaluate the subrecipient’s financial and administrative capacity during the risk assessment process in accordance with federal regulations.

Supplemental Subrecipient Documents (If Applicable)

Indirect Rate Agreement
The indirect rate agreement establishes the subrecipient’s federally negotiated indirect cost rate. This agreement is used to ensure the correct application of indirect costs in the project budget.

Fringe Benefit Rate Agreement
The fringe benefit rate agreement establishes the subrecipient’s approved fringe benefit rates. This is used to verify that fringe costs are applied accurately in the project budget.

Letter of Intent (LOI)
A letter of intent is a formal statement from the subrecipient confirming its commitment to participate in the project. This document is required only when specifically requested by the sponsor.

Other Sponsor-Required Certifications or Documents
Some sponsors require additional assurances or forms that are unique to their programs. These documents are collected only when needed to ensure compliance with the sponsor’s specific programmatic or regulatory requirements.

Issuing a Subaward

Once an award is made, the Subawards Team will initiate the subaward agreement process. This involves:

Verifying subrecipient information (including UEI, SAM.gov status, and vendor setup in MTSU’s financial system)

Conducting a subrecipient risk assessment

Preparing the subaward agreement and sending it to the subrecipient for signature

Routing the agreement through the appropriate MTSU departments for internal review and institutional signature

Finalizing and distributing the fully executed agreement

Establishing a Cayuse Subaward Form for the subrecipient (internal access only)

Timeline: The contracting timeline depends on factors such as subrecipient responsiveness, project complexity, and sponsor requirements. Early submission of required documentation helps expedite processing.

Subaward Amendments and Modifications

If changes are needed after a subaward is executed—such as extending the period of performance, increasing funding, or updating terms—the Subawards Team will prepare and route an amendment for signatures. PIs should notify the team as soon as a modification is anticipated to avoid delays.

Invoice Submission and Payment

Subrecipients are expected to submit invoices monthly or quarterly as outlined in their subaward agreement. All invoices must reflect actual, allowable, and allocable costs, align with the approved budget, and include supporting documentation (if applicable). Subrecipients are also responsible for following requirements related to invoice content, $0 invoice submission when no costs are incurred, and fiscal year-end deadlines.

Subrecipients should follow the guidance provided in the Subrecipient Invoicing Requirements document. This document may be attached to the subaward agreement at execution or provided separately, depending on the timing of the agreement.

Invoices should be submitted to MSTU Accounts Payable (invoice@mtsu.edu) with the Subawards Team (subawards@mtsu.edu) copied and must follow the format and instructions outlined in the subaward agreement or the invoicing guidance document. Payments are issued only after invoices are reviewed and approved to confirm compliance with both the subaward agreement and sponsor requirements.

Monitoring Subrecipients

As the prime awardee, MTSU is responsible for monitoring subrecipients to ensure compliance with federal, state, and sponsor regulations. Monitoring activities may include:

Reviewing technical and financial reports

Reviewing invoices to ensure costs are allowable and reasonable

Conducting desk reviews for higher risk subrecipients

Identifying and documenting performance or compliance issues for appropriate follow-up

These activities help MTSU meet its obligations as a pass-through entity under 2 CFR 200.

PI Monitoring Expectations
PIs play a critical role in monitoring subrecipient progress. This may include reviewing technical reports, verifying deliverables against milestones, documenting communications, and alerting the Subawards Team to any issues that could impact project performance or compliance.