Subaward/Subcontracting Information

Subcontracting, Sole Source Purchases, Large Equipment Purchases

Consult the Procurement Office when proposing subcontracts, sole source purchases and large equipment purchases.  Justification for sole source purchases should accompany the proposal packet sent to OSP  for review.

Services & Consultants

A service or consultant can be distinguished from a subaward by the nature of the work they will perform. An organization is considered a vendor service 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

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.

Note: Current UA employees CANNOT be paid as consultants on UAA proposals. However, emeritus faculty can be paid as consultants on UAA proposals only if:

  1. They have not been paid as a UA employee in the past 12 months;

  1. They are not doing a service that would fall under the normal scope of work of any UA employee;

  1. They are not using university resources such as office space, equipment, labs, etc. to perform the service(s);

  1. They are not being supervised on a day-to-day basis; and

  1. They are given a set task to complete with an expected deliverable.

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)

"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. 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.

Subawards

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 subaward 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.

Each UAA subrecipient organization is required to provide OSP with a Subrecipient Commitment Form . This form should be completed and signed by the Authorized Organization Representative (AOR) and the PI for the subrecipient. Along with this form, the subrecipient is required to include at a minimum:

  • A statement of work to be performed by the subrecipient organization/PI in the proposed project;

  • An itemized budget and justification for the work to be performed by the subrecipient;

  • Other documents as needed (i.e. CVs, C&Ps, copies of F&A or benefits agreements, copies of IRB or IACUC protocols, etc.)

UAA PI's who plan to be subrecipients on another institution's projects should check with the prime institution to determine what documentation is required. At a minimum, the Office of Sponsored Programs requires a statement of work, a budget and a budget justification(narrative).

Note regarding "Sub-subrecipients":  Unless substantial justification can be made, a subrecipient should generally not request any further sub-awarding of their portion of work. Instead, the prime awardee should budget all subawards/subcontracts so that they fall under the prime's authority.