When a research project requires scientific and scholarly contributions from external researchers, the Brown University Principal Investigator/Project Director may decide to include a request for a subaward in the proposal materials. A subaward collaboration is appropriate when another institution carries out a portion of the research project scope and has responsibility for some programmatic decision making. If the proposal is funded, the Office of Sponsored Projects, Research Subcontracting will formally establish the collaboration by entering into a subaward agreement with the collaborating organization.
The following guidelines describe various aspects of the subaward lifecycle.
Subrecipient vs. Contractor Determination
The first step in including a subaward in a proposal is to ensure that the collaboration is a subaward collaboration, as opposed to a contractor relationship. To assist with this determination, OSP recommends using the Federal Demonstration Partnership’s Checklist to Determine Subrecipient or Contractor Classification; a copy of this checklist can be found here.
Once a determination has been made that the collaboration with the other institution is a subaward collaboration, the following list of proposal materials are required for inclusion in the proposal when submitting to OSP for review. Depending upon the sponsor’s requirements, some of this information may be required in the full proposal submitted to the sponsor, while some information is for OSP records. The Sponsor’s submission guidelines will provide the best reference to determine whether these documents should be included in the full proposal submission.
Letter of Intent – A letter of intent from the collaborating institution is required. This letter must state the collaborating institution’s intent to accomplish the work as outlined in the scope of work; it must identify the Project title, the period of performance, and the funds requested; and it must be signed by the authorized official representative for the subrecipient institution.
Scope of Work – A Scope of Work provides sufficient detail of the technical and programmatic work to be accomplished by the Subrecipient, and it serves as the framework against which the subrecipient’s performance will be measured. The Scope of Work should clearly identify the subrecipient’s responsibilities. Please note that the Scope of Work will be published in a public database in accordance with the Federal Funding Accountability and Transparency Act, and should not include any proprietary or confidential information.
Subaward Budget – A subaward budget should include detailed subrecipient costs associated with the completion of the subaward scope of work. The subaward budget should identify Direct Costs and itemize such costs by major cost categories, such as salary, fringe benefits, equipment, travel, etc. If the Sponsor’s proposal guidelines allow for Subaward Indirect Costs, then the Subaward Budget may include Indirect Costs. The Subrecipient must provide a copy of its current Negotiated Indirect Cost Rate Agreement with the Federal government or other documentation to support the Indirect Cost rate request. Unless the Sponsor limits the recovery of Indirect Costs, the University may accept the rates established in the rate agreement.
Subaward Budget Justification – A budget justification providing the narrative description of the costs identified in the detailed budget is required. The budget justification should both identify the specific costs associated with each Direct Cost category and also provide justification to support the necessity of these costs for the completion of the subaward scope of work.
Other Documentation – In accordance with the Sponsor’s proposal guidelines, if additional subaward documentation is required, these should be included as part of the full proposal submission. An example of other documentation that is required includes Foreign Component information if the subrecipient is a foreign entity.
FCOI - Subrecipient Certification Form – If the sponsor of the proposed research project is NIH, then the Subrecipient Institution should complete and return a copy of our FCOI – Subrecipient Certification Form for inclusion in our internal proposal documents.
Requesting New Subawards
When the University receives a sponsored research award that includes a subaward, the PI/PD and Department Administrator should review the funding and work with the subaward to finalize the budget for the subaward agreement. Once a budget is finalized, the PI/PD and Department Administrators may complete a Subaward Order Form and submit the request to their OSP Research Subcontracting contact. If the Scope of Work or Budget and Budget Justification documents have been revised from the proposal documents, please include a copy of the updated documents with the SOF form. Submission of the New Subaward Order Form request initiates the OSP Research Subcontracting process for Subrecipient Monitoring and drafting the subaward agreement.
If the subaward is issued under NIH prime sponsored funding, then the subrecipient must either certify that they have a PHS/NSF compliant Financial Conflict of Interest (FCOI) Policy, or the subrecipient institution can agree that their researchers will follow Brown University’s FCOI Policy. The subrecipient institution indicates its selection on the FCOI – Subrecipient Certification Form that is included in the proposal materials. If the subrecipient institution indicates that its researchers will follow Brown University’s policy, then each subrecipient investigator will be required to complete the University’s FCOI training and submit a completed copy of the Non-Brown University Investigator FCOI Disclosure Form.
Under Federal funding grants and cooperative agreements, Brown University has a responsibility to conduct subrecipient monitoring throughout the award period of performance. There are two distinct elements of the subrecipient monitoring process: 1) a risk assessment of the subrecipient institution, and 2) an ongoing review of the subrecipient’s performance.
Subrecipient Monitoring – Risk Assessment
Subrecipient Monitoring takes place throughout the life cycle of a sponsored project. Information is gathered at the proposal and award stages as well as during an annual review process to ensure Subcontractor performance of the work and compliance with regulatory requirements. The University is required to verify Subrecipient eligibility and managing high risk Subrecipients.
If the proposed subaward is the first time that the University has collaborated with the subrecipient institution, then the initial subrecipient monitoring process will require the following documentation:
- either a completed Subrecipient Profile Questionnaire or an active profile on the Federal Demonstration Partnership’s Expanded Clearinghouse;
- copy of the subrecipient institution’s most recent Single Audit, audited financial statement, or other similar financial documentation—if this information is unavailable the subrecipient institution is required to provide additional explanation;
- a copy of the subrecipient institution’s most recent Indirect Cost Rate Agreement, if applicable; and
- if the subaward is funded under a Federally funded sponsored project, the subrecipient institution is required to maintain an active SAM.gov registration and have an active Unique Entity Identifier (UEI).
These documents or explanations are required for OSP Research Subcontracting to complete a Subrecipient Risk Assessment prior to issuance of the subaward agreement. Some factors that are considered when completing the Subrecipient Institution Risk Assessment includes such factors as the location, size, and age of the organization; the amount of the subcontract and the percentage of the prime award being subcontracted; the for-profit status of the organization; and the level of prior experience working with Brown.
Additionally, OSP Research Subcontracting screens subrecipient institutions and subrecipient Principal Investigators through the Visual Compliance database to determine if there are any restrictions on the institution or the individual from receiving federal funding.
A Note About Foreign Subrecipient Institutions:
If the proposed subrecipient institution is a foreign organization, and it is the first time that the University has collaborated with that institution, OSP strongly recommends that the PI/PD or Department Administrator contact the subrecipient organization at the time of proposal submission. The lead time for foreign organizations to provide this documentation and to complete SAM.gov registration can be significant.
Subrecipient Monitoring – Ongoing Review of Subrecipient Performance
During the term of a subaward, the PI is responsible for monitoring the activities of subrecipients, as necessary, to ensure that federal awards are being used for their authorized purpose and that performance goals are achieved. This monitoring is performed on a regular basis through such activities as regular communications with the subrecipient, interactions at technical meetings, review of progress reports, and review of invoices.
The invoice review process is a critical component of the ongoing subrecipient monitoring process as it provides an opportunity to address concerns prior to disbursement of funding. Our standard subaward template requires the subrecipient to submit invoices at least on a quarterly basis, and not more frequently than monthly. The subrecipient is required to submit the invoices directly to the Department Administrators and PI/PD for the project. The responsibilities for the subaward invoice review process are outlined in greater detail at the Subaward Invoicing Monitoring Best Practices.
Once the PI/PD has completed the invoice review process, the Department Administrators submit the invoices to Accounts Payable for payment.
Requesting Subaward Modifications
As the prime award is modified by our Sponsor, the project may require a modification to the subaward agreement as well. Subaward modifications are used to extend the period of performance, to increase the funded amount to append additional tasks to the Scope of Work, or modify other terms and conditions. To request a modification, the PI/PD and Department Administrators may submit a Change Order request to the Supplier Contract in Workday. The Change Order request should include a completed copy of the Modification Subaward Order Form, which indicates the modifications that are requested. If there are any other supporting documents for the modification, these should also be attached to the Change Order request.
Subaward Reporting Requirements
Depending on the Sponsor and the Sponsor’s funding mechanism, OSP Research Subcontracting is responsible for completing reporting of active subawards issued under Federal grants and cooperative agreements and Federal contracts under the Federal Funding Accountability and Transparency Act (FFATA). All FFATA reporting for the University is completed by OSP Research Subcontracting.
Subaward Close Out
If the subaward has ended and the PI/PD has received all technical reports, and if the final invoice from the subrecipient has been reviewed, approved, and paid, then the PI/PD and Department Administrators may request a close out of the subaward. The PI/PD should complete the Subaward Closeout Certification Form and submit a copy to the OSP Research Subcontracting Grant and Contract Administrator and to the OSP Post Award Grant and Contract Accountant.