Research Topic

Subaward Processing

Description

SPA is responsible for processing subaward agreements and amendments that are issued by the University to collaborating entities (subrecipients). SPA negotiators work with the principal  investigator(PI) and/or the unit to process subawards to other organizations who are to perform a distinct scope of work for a project.

The first step is a preliminary assessment of whether the entity is a subrecipient or a vendor.  This should be done at proposal stage so the budget can accurately reflect the correct expense type. If the subaward is not identified at proposal stage, the University may be required to seek sponsor approval. The below chart provides guidance to assist in determining whether the entity has a subaward or vendor relationship with regards to the prime award and the project work to be performed.

Subaward or Vendor?

Subawardee Vendor
Performs part of the “scope” of the research project and has its performance measured against such Provides goods and services to many different purchasers
Uses the funds to carry out a portion of the scope of work of the university’s research project Provides goods and services that are ancillary to the operation of the research project
Selected for intellectual merits or related research Operates in a competitive market
Responsible for compliance and flow down reporting requirements of the prime award Not subject to compliance issues (monitoring) or reporting requirements of the prime award
Has input into the decision making process regarding the direction of the research project Responds to specifications
Authors or co-authors publications Not applicable
May present papers/results of research at conferences Not applicable
May seek patent protection for inventions Not applicable
Retains title to intellectual property rights Work for hire—rights belong to buyer

Subaward requests must be submitted to SPA through the appropriate eForm. The eForm requests necessary information to initiate the drafting of the subaward agreement, such as the period of performance, amount of funds to obligate, and contact information.  The following items are also necessary and should be attached to the eForm.  Additional items may be needed depending on the circumstances and sponsor requirements

Scope of Work (SOW): The details of how the project work will be performed by the subrecipient. It should include a statement of the problem or issue to be investigated and the methods to conduct the investigation, as well as specific tasks to be performed. The SOW should also note the required deliverables and/or milestones for the project.

Budget and Budget Justification: A budget detailing the costs of the subrecipient’s project and appropriate justification should be included with the SOW. The budget should align with the proposed work and support the scope of the project.

Letter of Intent (LOI): A letter from the subrecipient institution's authorized official that approves their participation in the proposal submission. It should include the amount budgeted, period of performance, project details, indirect cost rate, and organizational information. This letter might also include cost-share detail or compliance related assurances associated with the project and/or specific sponsor (sponsor specific FCOI).

Federally Negotiated Indirect Cost Rate Agreement (NICRA): Subrecipients should provide a copy of their negotiated indirect cost rate agreement issued by their Federal cognizant agency (or external audit firm if the entity does not have a cognizant agency).  The agreement should state the indirect cost rate percentage and the period for which the rate(s) are valid. The indirect cost rate agreement submitted must be in effect as of the start date of the subaward agreement.

For Institutions of Higher Education, the applicable indirect cost rate remains fixed for the life of the subaward.  If the subrecipient does not have a negotiated rate, Uniform Guidance allows a de minimis rate to be used.  In cases when the prime sponsor limits the recovery rate of indirect costs, the limitation on the rate will flow down to the subrecipient.

As work progresses with the subrecipient, amendments may need to be issued for reasons such as extending the period of performance, obligating additional funding, or to make any changes to the terms and conditions of the subaward. Be mindful of the period of performance end date when planning for amendments.  There may be a need for the unit to request a no cost extension to allow for additional time to complete work.  The prime award will determine if a no cost extension is possible. The subaward end date cannot be extended beyond the prime award end date.

Units must initiate an amendment/modification action via the eForm. If there are any concerns with subrecipient performance, invoicing, reporting, etc. an amendment is an opportunity to discuss options with SPA. We may be able to address the situation through added or clarified terms and conditions.

Additionally, there are instances when administrative or financial changes to the prime award should be communicated to all the subrecipients. In these instances, SPA will communicate the change through amendments.

Need help completing the Subaward eForm?

Job aid for New Subawards

Job aid for Subaward Modifications

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