Research OSPA:Subcontracts-in Process
September 1, 2013
Statement of theIssue
If UTD will participate as a subrecipient in a grant application submitted to a sponsor by another institution or organization as the prime (a.k.a. pass-through entity or federal award recipient), the Office of Sponsored Projects (OSP) is required to submit to the prime institution or organization official endorsement of UTD’s participation and commitment of personnel and resources to the proposed project. UTD as a subrecipient will be conducting a specialized and specific portion of the project that is the subject of the submitted proposal.
- UTD Sponsored Programs Administration UTDBP3032
- The prime institution or organization is responsible for establishing compliance with the <a class="wiki external" target="_blank" data-cke-saved-href="http://www.gpo.gov/fdsys/granule/CFR-2014-title2-vol1/CFR-2014-title2-vol1-sec200-330" href="http://www.gpo.gov/fdsys/granule/CFR-2014-title2-vol1/CFR-2014-title2-vol1-sec200-330" rel="external">Office of Management and Budget (OMB) Uniform Guidance (UG), Section 200.330-332</a>
- Types of compliance requirements include: activities allowed or unallowed; allowable costs/cost principles; cash management; eligibility; matching, level of effort, earmarking; and reporting.
- Recipients shall apply the provisions of the UG to subrecipients performing substantive work under agreements that are passed through or awarded by the primary recipient if such recipients are higher education, hospitals, or non-profit entities.
- The documents required to participate as a subcontractor include the following:
- Letter of commitment signed by an authorized organizational representative (AOR) who can contractually commit the institution/organization to participate in the proposed project. The UTD AOR is the Assistant Director, Office of Sponsored Projects, the Associate Vice President for Research or the Vice President for Research.
- Statement of Work (the description of the work to be performed and completed by the subrecipient)
- Budget and budget justification
- Period of performance
- Project title
- Solicitation number or weblink
- Copy of negotiated Facilities and Administrative (F&A) Cost Agreement
- Visual Compliance checks
- Export control checklist
- Cert form fully signed
- Additional documents, as needed
- Current and pending
- Facilities and other resources
- Research compliance approvals (e.g. IRB, IACUC, Human Subjects training, etc.)
- Either the Principal Investigator (PI) or Grants Specialist will submit the subcontract documents to the prime institution or organization
- Once awarded, the PI and their administrative staff should be advised to follow the <a class="wiki external" target="_blank" data-cke-saved-href="https://research.utdallas.edu/opm/guidelines/subrecipient-monitoring/" href="https://research.utdallas.edu/opm/guidelines/subrecipient-monitoring/" rel="external">Office of Post Award Management process</a>
In accordance with the UTD submission deadline policy, all finalized subcontract documentation should be prepared and submitted to the OSP office for review at least four (4) business days prior to the submission deadline. If said documentation cannot be provided at least four business days prior to the submission deadline, then the UTD PI should obtain written permission to submit from the Associate Vice President or Vice President for Research.
- Catalog of Federal Domestic Assistance (CFDA): Contains detailed program descriptions for 2,209 Federal assistance programs. The top five issuing agencies include: Department of Health and Human Services, Department of Interior, Department of Agriculture, Department of Justice, and Department of Education. These federal programs are available to state and local governments (including the District of Columbia); federally-recognized Indian tribal governments; Territories (and possessions) of the United States; domestic public, quasi-public, as well as private profit, nonprofit organizations, and institutions; specialized groups; and individuals.
- Flow-through funds: Monies that are passed from the Recipient to a secondary entity or Subrecipient
- Flow-down or Flow-through: Applying the terms and conditions in the Prime Award to the Subaward
- Pass-through entity: A non-federal entity that provides a federal award to a subrecipient to carry out a federal program
- Prime Award: The grant/contract from the awarding agency (funds the subaward)
- Recipient: A non-Federal entity that expends federal awards received directly from a federal awarding agency to carry out a federal program
- Subaward: An award of financial assistance in the form of money, or property in lieu of money, made under a prime award by the prime recipient to an eligible subrecipient or by a subrecipient to a lower tier subrecipient. The term includes financial assistance when provided by any legal agreement, even if the agreement is called a contract, but does not include procurement of goods and services.
- Subrecipient: The legal entity to which a subaward is made and which is accountable to the recipient for the use of the funds provided. The activities of a subrecipient will have significant impact on the total project with distinct deliverables for work that is unique to the project. The terms of UTD subrecipient relationships are documented in subcontract or consortium agreements.
- Uniform Guidance- In effect December 26, 2014 and published by the federal Office of Management and Budget (OMB), this guidance supersedes and streamlines requirements from OMB Circulars A-21, A-87, A-110, and A-122; Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up. This guidance provides a government wide framework for grants management which will be complemented by additional efforts to strengthen program outcomes through innovative and effective use of grant-making models, performance metrics, and evaluation. <a class="wiki external" target="_blank" data-cke-saved-href="http://www.whitehouse.gov/omb/grants_docs" href="http://www.whitehouse.gov/omb/grants_docs" rel="external">http://www.whitehouse.gov/omb/grants_docs</a>