In the beginning, check the Proposal File
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.
Subaward or a Professional Services Vendor Agreement--which do I request?
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.
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.Note regarding "Sub-subrecipients": Unless substantial justification can be made, a subrecipient should generally not request any further subawarding of their portion of work. Instead, the prime awardee should budget all subawards/subcontracts so that they fall under the primes authority.
A subaward may be appropriate if you can answer yes to any of the following:
When to request a Professional Services Contract?
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.
A procurement action may be appropriate when the entity:
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:
Treating Vendor Services as Subawards
All items deemed services will have full F&A charged against them, unless it can be demonstrated that the vendor can be treated as a subaward under the following policy:
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 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.
How to determine whether grant and subgrant agreements are overloaded
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.