The Institute must fulfill its Pass-Through Entity responsibilities when including Subawards in proposed Sponsored Awards. PI/PDs and unit administrators must identify Subawards, as defined in this Policy, in proposed budgets and budget revisions, to ensure that costs are calculated correctly, sponsor approval is obtained, and appropriate documentation is included in the Institute’s proposal. 

When it is the Pass-Through Entity, the Institute is responsible for:

• Assessing the substance of the relationship between the Institute and the entity to which it is flowing through Sponsored Award funding;
• Based on the above assessment, following federal guidelines for accurate classification of Subawards (2 CFR 200.331 Subrecipient and contractor determinations); and
• For identified Subawards, complying with federal and sponsor-specific requirements for Subrecipient management and monitoring, including:
  • 2 CFR 200 Subpart D - Subrecipient Monitoring and Management
  • Terms and conditions of prime awards including applicable sponsor regulations (e.g. Federal Acquisition Regulation (FAR)) and requirements.

For purposes of this policy, Subawards include Subcontracts the Institute issues under its sponsored Contracts if they meet the Institute’s criteria for accurate classification of Subawards. Such agreements issued under federal Contracts are subject, also, to the FAR and any applicable funding agency supplemental regulations. The State of Georgia considers all agreements for goods and services to be contracts and, therefore, the Institute must also comply with state procurement requirements in issuing and managing Subawards. 

The Institute’s procurement Contracts and other purchases of supplies and service that do not meet the Institute’s criteria for accurate classification of Subawards are not subject to this policy.