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Sponsored Project Subawards

Sponsored Project Subawards

Effective Date: April 1, 2008

Revised:  September 24, 2008

January 26, 2010

July 1, 2015

Policy Statement

As the recipient of a primary award for a Sponsored Project, Columbia University (Columbia or the University) may award financial assistance to a Subrecipient to facilitate performance of and payment for specific work to be conducted by such Subrecipient in connection with the Sponsored Project.  As a condition to its acceptance of funding from a sponsor, the University is obligated in its role as recipient of the primary award to undertake certain stewardship activities and to ensure compliance by the Subrecipient with federal, state and local laws and regulations and with the restrictions placed upon the primary award by the sponsor.  When the University assigns responsibility for conducting a portion of the work under the primary award to a Subrecipient, the University remains responsible to the sponsor for managing funds and meeting performance goals.  This responsibility involves (a) pre-award assessment of the proposed Subaward and Subrecipient, (b) post-award monitoring of the programmatic and financial activities of the Subrecipient under the Subaward and (c) at close-out, determination that applicable administrative tasks and project work have been completed by the Subrecipient.This Policy applies to Subawards issued in connection with Sponsored Projects undertaken by investigators at the University regardless of the primary source of funding.

This Policy reflects the provisions of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (CFR, Title 2) (the Uniform Guidance), and in particular Sections 200.330-200.332 thereof, that was issued by the federal Office of Management and Budget (OMB) on December 26, 2013 and became effective for federal agencies as of such date and for non-federal entities, such as the University, as of December 26, 2014. The Uniform Guidance supersedes, among other regulations, OMB Circulars A-110 and A-133.

Reasons for the Policy

This Policy seeks to:

  • ensure that risks associated with a Subrecipient or sponsored project are identified and managed prior to the issuance of a Subaward;
  • ensure Subrecipients and Contractors are classified appropriately;
  • promote compliance with federal, state and local laws relating to Subrecipient monitoring; and
  • assign appropriate unit-level and individual responsibility and accountability for the establishment, management and monitoring of Subawards.

Primary Guidance to Which This Policy Responds

This Policy primarily responds to the Uniform Guidance:

2 CFR §200 (Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards) (


Responsible University Offices and Officers

Sponsored Projects Administration

Office of the Controller, Research Policy and Indirect Cost Division


Revision History

The effective date of this Policy is July 1, 2015. This Policy replaces the Policy on Sponsored Project Subawards, effective April 1, 2008 and revised September 24, 2008 and January 26, 2010.


Who is Governed by this Policy

Faculty and staff who are responsible for authorizing, processing and monitoring Sponsored Project Subawards.


Who Should Know this Policy

      1.  All persons governed by this Policy [see above]

      2.  Principal Investigators

      3.  Departmental Administrators and other departmental staff

      4.  Deans and Department Chairs

      5.  Office of Research Administration

      6.  Office of the Controller


Exclusions and Special Situations

Not applicable


Policy Text

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