Subawards & Subcontracts
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 provider 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:
- They have not been paid as a UA employee in the past 12 months;
- They are not doing a service that would fall under the normal scope of work of any UA employee;
- They are not using university resources such as office space, equipment, labs, etc. to perform the service(s);
- They are not being supervised on a day-to-day basis; and
- 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:
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 applies F&A to 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.
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.
Creating a Subaward
After determining you need to issue a subaward, please review the subaward routing process and submit the necessary forms below.
Subaward Routing Process
- Fill out subaward enterable forms and necessary attachments
- Enter subaward requisition on Banner with complete Document Text that answers the following questions:
a. Who requested the subaward (e.g. PI name)?
b. Who is entering the requisition and phone number?
c. What is the performance period?
d. How does this benefit/relate to the project?
e. Other pertinent information?
- Email enterable, not scanned, subaward document and attachments to your Grant Coordinator
and cc email@example.com; include the requisition and fund numbers on the email subject line
(e.g. R0XXXXXXX; 2XXXXXX; Subaward Agreement)
Grants & Contracts Personnel:
- Grant Coordinator will enter receipt of documents in Access Subaward Log and review subaward forms and attachments
- Grant Coordinator will print one copy for Director's review and signature
- Grant Coordinator will approve requisition and will email a scanned copy to Department Personnel and Procurement (firstname.lastname@example.org)
- Procurement will send signed agreement to subrecipient for signature(s)
- Procurement will assign PO once fully executed subaward is received
- Procurement will email a copy of fully executed subaward to department and G&C
FDP Subaward Templates
- FDP Main Subaward Agreement and 3A Prime Contacts
- FDP Subaward 3B Page 1 Recipient Contacts
- FDP Subaward 3B Page 2 Place of Performance & Highest Compensated Officers
- FDP Attachment 2 Prime Award and Special Terms & Conditions
- FDP Attachment 4 Reporting Requirements
- FDP Attachment 5 Scope of Work
- FDP Attachment 6 Budget & Justification
- FDP Attachment 7 Sample Invoice
- FDP Attachment 8 OMB A-133 Audit Compliance
- FDP Attachment 9 Subrecipient Monitoring Form
Non-FDP Subaward Templates
- Non-FDP Main Subaward Agreement and Attachment 2
- Non-FDP Attachment 3 Recipient Contacts
- Non-FDP Attachment 4 Terms & Conditions
- Non-FDP Attachment 5 Scope of Work
- Non-FDP Attachment 6 Budget & Budget Justification
- Non-FDP Attachment 7 Sample Invoice
Subrecipient Risk Assessment
As required under OMB A-133, UAA Procurement completes a risk analysis of the subrecipient prior to issuing the subaward. If a subrecipient is found to be high-risk, the subaward may include the following items:
- Corrective Action Plan
- On-site monitoring
- More detailed invoicing
- Receipt of technical progress reports tied to payments
- More stringent termination language for failure to comply with requirements
Amending a Subaward
The Principal Investigator determines when a subaward is to be amended. Common reasons for amending a subaward include providing additional funding, extending the period of performance, or modifying the reporting schedule. It is important to note that some changes, such as scope of work changes, change in the subaward recipient's Principal Investigator or transferring the subaward from one recipient to another, may require the prior approval of the prime sponsor (funding agency).
Here are the steps in amending a subaward:
1. Fill out and email the Subaward Modification form and any attachments (i.e. new budget, revised scope of work) to your grant coordinator. Here is an example of a subaward modification form. Any attachment needs to be on enterable forms/versions (i.e. Word, Excel). Scanned forms will not be accepted.
2. Email Procurement and cc your grant coordinator a change order request:
a. Subject line: P0xxxxxx; Gxxx; subaward change request
b. State in the email what the change request is (i.e. increase/decrease budget, payment schedule)
3. After Grants & Contracts approves the modification, your grant coordinator will forward the signed hardcopy modification and any attachments to Procurement Services; you will receive a scanned copy of the signed modification. Procurement Services will process your change request on Banner, contact you if additional procurement forms are required, and will forward subaward modification to the subrecipient.
FFATA Requirements for Amended Subawards
For Federal awards, the FFATA Subaward Reporting System (FSRS) will collect data from the Federal prime awardees on subawards they make: a prime grant awardee will be required to report on its subgrants and a prime contract awardee will be required to report on its sub-contracts.
For those new Federal grants as of October 1, 2010, if the initial award is equal to or over $25,000, reporting of subaward and executive compensation data is required.
- If the initial award is below $25,000 but subsequent grant modifications result in a total award equal to or over $25,000, the award will be subject to the reporting requirements, as of the date the award exceeds $25,000.
- If the initial award equals or exceeds $25,000 but funding is subsequently de-obligated such that the total award amount falls below $25,000, the award continues to be subject to the reporting requirements of the Transparency Act and this Guidance.
Closeout of a Subaward
The Principal Investigator is the delegated individual with authority for the University of Alaska Anchorage to tell Accounts Payable when the final payment can be issued and the subaward should be closed. Until the Principal Investigator verifies that all elements of the subaward have been satisified, UAA cannot call the subaward "a wrap".
The University PI should contact the subrecipient 90 days prior to the end of the period of performance to confirm the status of the project. To successfully close out the subaward, the University PI must do the following:
- Follow up on late or missing reports or deliverables
- Obtain the final invoice – clearly marked “FINAL”
- Send a copy of the approved final invoice to Accounts Payable for processing
(NOTE: Any outstanding issues with the subrecipient should be resolved prior to approving the final invoice for processing.)
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