UW Research
Policies, Procedures and Guidance

GIM 07 – Sponsored Program Subaward Administration

Purpose

This GIM sets out the policy for administration of subawards issued by the University (UW) under a prime award.

When the UW issues a subaward, it maintains responsibility to the prime sponsor for managing the funds and ensuring performance and compliance expectation under the prime award. This policy covers subaward issuance, responsibilities related to administration of subawards, and compliance with federal, state and local laws. Subrecipient Monitoring policy is covered under GIM 8.

Background

A subaward is a special type of agreement that differs in several respects from those for the more standardized procurement of goods and services from contractors.

Subawards are issued by the Office of Sponsored Programs (OSP). The issuance of a contract to procure goods and services is managed by Procurement Services.

The prime sponsor’s award to the UW usually includes specific authorization for the subaward. Occasionally, the need for a subrecipient’s collaboration develops after an award has been made to the UW. Under those circumstances, most sponsor policies require sponsor approval for the subaward before it is issued.

University Policy

To ensure compliance with the prime sponsor funding, regardless of the sponsored program funding source, the Office of Sponsored Programs (OSP) prepares and administers subawards according to sponsor policies found in the prime award.

Subawards can only be issued when:

  • The prime award has been received and set up in the UW financial system
  • Subaward is authorized under the prime award
  • OSP receives a complete and correct subaward request

Subawards under Sponsored Awards may only be issued and signed on behalf of the UW by the institutional officials with delegated signature authority within OSP. OSP is only authorized to handle subawards under sponsored awards.

Identification of Subrecipients

The UW Principal Investigator (PI) determines the need for collaborations during proposal planning and preparation. Many times, this determination results in the need for a subaward. The PI’s identification of a subrecipient is primarily based on the unique expertise, qualifications availability, cost and technical resources of the subrecipient.

Sometimes it is difficult to distinguish the appropriate agreement type that is needed for the collaboration (subaward or procurement contract). Review Subrecipient, Vendor/Contractor, Consultant?

If it is still unclear what type of agreement is appropriate, the OSP subaward team will make the final decision about whether a subaward is the appropriate agreement.

As a state institution, the UW must justify sole source selection. The PI is responsible for documenting sole source selection justification of the proposed subawardee and maintaining the justification within departmental files.

Preparing Proposals that Include Subrecipients

The following subrecipient components must be provided in the eGC1 for a proposal:

  • Subrecipient’s Scope of Work (SOW): A description of the work to be performed by the subrecipient, including a timeline for reports and deliverables.
  • Subrecipient’s budget and budget justification: Includes the subrecipient’s direct and Facilities & Administrative costs (F&A).
    • If the UW’s prime sponsor has a published policy capping F&A rates, this capped rate applies to the subrecipient.
    • If the subrecipient does not have a federally negotiated F&A rate, and in the absence of a prime sponsor F&A rate cap, the maximum F&A rate the subrecipient may use is 15% Modified Total Direct Costs (MTDC) or other rate that subrecipient has been awarded under another federal award.
  • Approval from the Subrecipient’s institutional official: Which includes the project period, amount, and project title of the subrecipient’s proposed scope of work.
  • Any additional elements the prime sponsor requires in the proposal.

All costs for subawards should be categorized on the UW proposal budget in the appropriate Object Class (08_Subaward) within the proposal budget. Follow any other sponsor requirements for representing subawards within the sponsor proposal budget.

Each proposed subaward must be associated with only one anticipated award.

Subaward Request & Issuance

The PI or designated UW Campus Unit staff cannot request a subaward until the award or award modification has been set up in the UW Financial System. All supporting documentation (e.g. current budget, budget justification, and subrecipient SOW) must be attached to the subaward request in SAGE.

OSP drafts and issues the subaward agreement to the subrecipient according to sponsor and UW policies or requirements. If necessary, OSP and the subrecipient negotiate to reach an agreement on terms and conditions that comply with sponsor requirements, UW policies, and subrecipient policies.

Subawards are typically funded on an annual basis. Subaward modifications are used to incorporate changes to the subaward as required by the project, sponsor, or other need to change the terms and conditions of the subaward.

Closeout of a Subaward

The PI/Department is responsible for handling sponsor closeout requirements.

Review more information on subaward closeout.

Responsibilities

Principal Investigator

Office of Sponsored Programs

  • Review and submit proposals to prime sponsor according to GIM 1
  • Carry out entity level subrecipient monitoring according to GIM 8
  • Draft, issue, and negotiate the subaward
  • Execute and distribute subaward, including upload the final agreement and modifications in the SAGE record
  • Prepare and issue subaward modifications
  • Prepare and submit federally required FFATA reports related to subawards

Related Resources

Contacts

Change Notes

Details on changes to this GIM are available from the Office of Sponsored Programs, osp@uw.edu