- Preparing and Negotiating Subawards
Subaward Agreements are issued to a third party when projects require expertise and/or facilities not available at Clemson University. Subaward Agreements are prepared and negotiated by the Subaward Manager in Grants and Contracts Administration. Once the subrecipient and Clemson University’s authorized official sign the subaward agreement, it is sent to the appropriate Grants Manager in Grants and Contracts Administration for purchase order set up. Subrecipients must be registered in the Clemson University's BuyWay$ system to receive payment for submitted invoice(s).
- Monitoring Subawards
The PI is responsible for certifying technical progress and expenditures. The PI must review and sign the subrecipient’s invoices before payment is made. In signing and/or approving the invoice for payment, the PI’s signature implies that the charges appear reasonable and progress to date is satisfactory in keeping with the statement of work. Approval may be performed via e-mail. Grants and Contracts Administration is responsible for 1) monitoring expenditures and ensuring the total subaward agreement is not exceeded, 2) ensuring that required audits and risk assessments are performed, and 3) requiring corrective action on findings.
- Changes in Subawards
Any changes needed in the subaward agreement should be discussed with the Subaward Manager in Grants and Contracts Administration to determine if the subaward agreement can be amended or changed. If a new subaward agreement is needed during the life of the project, the Subaward Manager in Grants and Contracts Administration will negotiate the subaward agreement.
- Closing Subawards
When the final invoice is received, the invoice is sent to the PI for approval and signature. This signature verifies all contract work has been satisfactorily performed and payment is authorized.
- Program Income
It is important to correctly identify Program Income from PI/Department Self-Generated Income as program income must be accounted and reported to our Federal Sponsors. The treatment of Program Income is regulated by the OMB Uniform Guidance section 200.307 and “must be used for the purposes and under the conditions of the Federal award”.
Program income is revenue generated when the goods or services, for which an individual is charged, are directly generated by a sponsor award during its period of performance. It may be necessary to review the specific award(s) or the awarded proposal to make this determination.
Examples of Program Income may include:
- income from fees for services performed such as laboratory tests;
- income received from others using equipment purchased with grant funds;
- funds received for the use or rental of real property, equipment or supplies acquired under the grant;
- the sale of commodities or items fabricated under an award;
- charges for research resources;
- registration fees for grant-supported conferences or symposia;
- proceeds from the sale of software, publications, or media;
- income from the sale of research materials;
- sales of products with an accompanying material transfer agreement.
Unless awarding agency regulations or the terms and conditions of the award provide otherwise, income earned from license fees and royalties for copyrighted material, patents, patent applications, trademarks and inventions are under no obligation to the federal government.
Methods and Use
- Deduction - Ordinarily program income must be deducted from total allowable costs to determine the net allowable costs. Program income must be used for current costs unless the Federal awarding agency authorizes otherwise. Program income that the non- Federal entity did not anticipate at the time of the Federal award must be used to reduce the Federal award and non- Federal entity contributions rather than to increase the funds committed to the project.
- Addition - With prior approval of the Federal awarding agency, program income may be added to the Federal award by the Federal agency and the non-Federal entity. The program income must be used for the purposes and under the conditions of the Federal award.
- Cost sharing or matching - With prior approval of the Federal awarding agency, program income may be used to meet the cost sharing or matching requirement of the Federal award. The amount of the Federal award remains the same.
For Federal awards made to Institutions of Higher Education and nonprofit research institutions, if the Federal awarding agency does not specify in its regulations or the terms and conditions of the Federal award how program income is to be used, the addition method referenced above will apply.
Determination and Identification:
When known, any anticipated program income should be included in the proposal budget and budget justification when submitting to the sponsor. Principal Investigators (PIs), Department and College Post-award personnel are responsible for the proper identification of program-related income and ensuring the proper deposit during the performance period of an award. If you are uncertain whether monies received should be classified as program income, please contact a Grants and Contract Administration (GCA) representative for assistance in making a determination.For additional information, please refer to the Clemson’s Program Income Procedure.
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