Subawards and Contracts

District Requirements

All agreements and sub-award agreements must follow District contract, insurance and board approval requirements, including: 

Purchasing Procedures and Contract Requirements 
Board Policy 2.45 Conflict of Interest 
Administrative Procedure 2.45.1 Conflict of Interest
Administrative Procedure 2.45.2 Conflict of Interest Code

For additional details, see 2 CFR §200.318 (c)(1) .


A sub-award means an award provided by a pass-through entity to a sub-recipient for the sub recipient to carry out part of a Federal award. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A sub-award may be provided through any form of a legal agreement. (SMCCCD would be the pass-through entity.) Sub-recipients may also be a recipient of other Federal awards directly from a Federal awarding agency.

All sub-award agreements must include the following:

  • Federal award number
  • Federal awarding agency
  • Award date
  • DUNS number of sub-recipient
  • Sub-recipient name and it must match registered name in DUNS
  • Sub-award period of performance start and end date
  • Amount of federal funds obligated by the sub-award
  • Total amount of federal award
  • Project description
  • Scope of work by sub-recipient
  • Contact information for awarding official
  • CFDA (Catalog of Federal Domestic Agency) number and name
  • Federal Negotiated Indirect Cost Rate
  • All statutes, regulations and the terms and conditions of the federal award
  • Financial and performance report requirements
  • Permission to access sub-recipient’s records and financial statements as necessary during the
           performance period to meet audit requirements
  • Sub-award close out terms and conditions
  • Debarment statement

Risk Assessment

The pass thru entity (District/College) must evaluate sub-recipient’s risk of noncompliance. This could be done thru review of previous audits. If there were findings, review and evaluate that actions taken were timely and appropriate to eliminate the findings. In addition, a review must be done of the sub- recipient’s Exclusion Records in the System for Award Management (SAM) website to ensure no risk. Risk assessment should be completed prior to a commitment.

All invoices and reports must include the certification, “By signing this report, I certify to the best of my knowledge  and  belief  that  the  report  is  true,  complete,  and  accurate,  and   the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (U.S. Code Title 18, Section 1001 and Title 31, Sections 3729–3730 and 3801–3812).’’