Including a Subrecipient on Proposal Submissions

Overview

A Subrecipient (also called a subcontractor or subawardee) is an organization eligible to receive a financial award. A subrecipient’s performance is measured against whether the objectives of the sponsored program are met; subrecipients have responsibility for programmatic decision-making and for adherence to applicable program compliance responsibilities. Subrecipients are responsible for performing a substantive portion of the program, as opposed to providing goods and services.

If an award is made to Harvard, a subagreement is issued to the subrecipient to conduct their portion of the proposed work. A subagreement is an enforceable agreement, issued under a prime sponsored project, between a pass-through entity and a subrecipient for the performance of a substantive portion of the program; these terms do NOT apply to the procurement of goods or services from a contractor (vendor). (See Subrecipient vs. Contractor Guidance.)

As Defined by Uniform Guidance

A Subrecipient means a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency (Uniform Guidance §200.93).

A Subaward is an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract (Uniform Guidance §200.92).

Proposal Development Stage

  • In consultation with the Principal Investigator, the Department Administrator identifies if there will be a portion of the work conducted by a subrecipient organization.
  • If a subrecipient is included in the proposal, the question “Are subrecipients included in the proposal?” should be answered “yes,” the subrecipient module should be completed, and subagreement costs should be entered in the GMAS proposed initial request budget.  
  • The Department Administrator works with the PI and the subrecipient to collect documents required by OSP and the sponsor.
    • When a proposal to NIH includes a subaward to a foreign organization, either: ​​​​​​
      • The foreign organization must complete and sign Harvard’s Statement of Intent, or
      • The following provision is required by Harvard University in the foreign organization’s statement of intent.
        • ​​​​​​​​​​​​​​The subrecipient organization agrees to abide by the requirements of the NIH Final Updated Policy Guidance for Subaward/Consortium Written Agreement (NOT-OD-23-182), and will provide access to copies of all lab notebooks, all data, and all documentation that support the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic.
  • OSP completes a risk assessment for all new subrecipients in the subrecipient’s organizational profile in GMAS when funding is awarded.
  • For more information, please refer to the Subrecipient Monitoring Toolkit.
  • The OSP Proposal Review team reviews subrecipient proposal documents as part of the overall proposal review process and will submit the required documents with the prime proposal.

Required Elements

When a Harvard proposal includes a subaward, the following elements are required:

  • Complete the Subrecipient Module in the GMAS Initial/Competing Request
    • Enter anticipated budget periods for subrecipient
  • Enter proposed subrecipient costs in the GMAS initial request proposed budget for each budget period
  • Create a Folder in the GMAS initial request document repository named “Subrecipient (subrecipient institution name)”, upload sub documents, select the corresponding document category (if applicable) and associate the document to the appropriate subagreement:
    • Statement of Intent signed by Authorized Official for the subrecipient:​​​​​​​
    • When a proposal to NIH includes a subaward to a foreign organization, either: ​​​​​​
      • ​​​​​​​The foreign organization must complete and sign Harvard’s Statement of Intent, or
      • The following provision is required by Harvard University in the foreign organization’s statement of intent.
        • ​​​​​​​​​​​​​​​​​​​​​The subrecipient organization agrees to abide by the requirements of the NIH Final Updated Policy Guidance for Subaward/Consortium Written Agreement (NOT-OD-23-182), and will provide access to copies of all lab notebooks, all data, and all documentation that support the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic.

Please note: If subrecipient’s proposed budget and/or SOW change during the proposal review process, the department needs to obtain revised signed documents from the Subrecipient.

Calculating Subaward costs into Harvard’s F&A Base

Federal Proposals

  • The first $25K of the subrecipient’s total costs, must be included in Harvard’s MTDC.
  • If the subaward in year 1 is less than 25K, then Harvard’s F&A for the 2nd year must include the balance.

Non-Federal Funds

  • The process for applying F&A varies among non-federal sponsors.
  • The 25K federal cap may apply. Check sponsor guidelines.
  • If there is no sponsor cap specified in the sponsor’s guidelines, F&A must be applied to the full subaward amount.

Award Stage

Please see additional information on requesting subagreements and subamendments during award stage at “Managing a Subagreement."