The UAA proposal reviewed and approved by the Office of Sponsored Programs (OSP) at the University of Alaska Anchorage should have determined the type of relationship UAA would have to enter into should the project be funded.  Post-award Grand Coordinators will review the Proposal File to verify that a Subrecipient Commitment Form was agreed to prior to the submission of the initial proposal to the funding agency.  The Director of the Office of Sponsored Programs at UAA should have already clarified if this is a vendor or a subaward relationship.

When to request a Subaward?

A subaward is needed when the intent is to have another organization help carry out a portion of the scope of work described in the proposal.  A subaward or subcontract can be distinguished from a service or consultant by the nature of the work they will perform.

• An organization is considered a subawardee when it:
• Makes substantial contributions to the project that may not be reduced to a set price per unit;
• Has its performance measured against whether the objectives of the project are met; and
• Has responsibility for programmatic decision making.

UAA requires specific documentation to certify commitment of each subrecipient. Remember, the university claims F&A recovery on only the first $25,000 of each subaward, even if the project spans multiple years.

A subaward may be appropriate if you can answer yes to any of the following:

• Does the entity's statement of work represent an intellectually significant portion of the programmatic effort of the overall project?
• Does the entity have responsibility for programmatic decision-making?
• Is there an identified Principal Investigator for the entity? Is he or she a Co-Investigator on the primary proposal?
• Could the entity's work result in Intellectual Property developed?
• Are publications anticipated from the entity? Will individuals at the entity be co-authors on articles?
• Will the entity need animal (IACUC) and/or human subject (IRB) approval for its portion of the work?
• Is the entity providing cost sharing or matching funds?

When to request a Professional Services Contract?

• A Professional Service Vendor or Consultant can be distinguished from a subawardee by the nature of the work they will perform. A professional services contract is considered a vendor when it:
• Provides similar goods and services to different clients within normal business operations;
• Operates in a competitive environment; and Provides goods and services ancillary to the operation of the program at a set price per unit

Professional Service Contracts (Agreements) include all expenses to be incurred for services during the project period, such as: media services, computer services, lab analyzes, consulting, animal care, boat and air charters. Services also include both oral and written communication costs related to the project such as toll charges, fax, postage, and publication costs. When describing consultant costs in the budget justification, mention any consulting fees and address why the individual is required for the task.

Services not requiring a subaward are covered by the financial policy of the UAA Procurement Services.

A procurement action may be appropriate when the entity:

• Is to perform a series of repetitive tests or activities requiring little or no discretionary judgment (e.g. Entity performs a test on data we provide to them and gives us the results to analyze.).
• Provides the goods and services within its normal business operations (e.g. Entity regularly sells the goods or services as a part of their routine business operations, usually at a fixed price or rate (e.g., pipettes, tanks of hydrogen, etc.)).
• Provides similar goods and services to many different purchasers.
• Operates in a competitive environment.
• Is not subject to the compliance requirements of the prime sponsor.

FAQ's

Can current UAA employees be paid as consultants?

Current employees, whether staff or faculty, may not be paid as a a consultant to the University of Alaska.  However, Emeritus Faculty can be paid on a Professional Services Agreement as consultants on UAA proposals only if:

1. They have not been paid as a UA employee in the past 12 months;
2. They are not doing a service that would fall under the normal scope of work of any UA employee;
3. They are not using university resources such as office space, equipment, labs, etc. to perform the service(s);
4. They are not being supervised on a day-to-day basis; and
5. They are given a set task to complete with an expected deliverable.

Treating vendor services as subawards (from UA Statewide see Administrative Services Manual D-07)

"If a department believes that it has a contract for allowable goods and services that should not recover F&A costs on the excess over $25,000, that department must be able to clearly demonstrate that the contract does not require the same level of F&A support as other contracts for goods and services. To qualify for the exclusion, the vendor contract must meet the following criteria:

• The contract must be in excess of $50,000.
• Normally, the primary administrative costs associated with the contract are only the initial costs incurred in the bidding process.
• Limited additional administrative costs will be incurred as a result of the short-term of the contract, few types of goods and/or services purchased, quantity of goods purchased is small, or the vendor will receive a small number of payments.

The unit should follow the same process used by their respective MAU for F&A waivers by providing a written request explaining the need and justification for exceptional treatment to their respective campus’s Chief Financial Officer or authorized designee for review and approval. MAU's that currently charge a penalty to departments for waivers have the option of treating these situations as exceptions to those penalties."

NOTE: In these cases, fill out the Request for Waiver to Treat Vendor Service Contract as Subaward form. Object codes 3028 and 3029 will be the object codes used for these agreements.  Notice of intent to seek a waiver should be given to OSP as far in advance as possible. There are no guarantees that a waiver will be granted and it could require the budget to be changed, so lead time is key with these request. This form will be required for such requests and should be included with the proposal package to OSP. The memo is an internal document only for review and approval of a waiver.

Many federal grant agreements and sub agreements contain requirements that are not necessary for administering a particular grant award.  Federal agency officials, grant recipients and sub recipients should review their agreements for unnecessary terms and conditions.