Subrecipients Under Uniform Guidance

Research Administration News Subrecipients Under Uniform Guidance

Subrecipients Under Uniform Guidance

​Per the new Uniform Guidance regulations, which became effective December 26, 2014, UAB “…must make case-by-case determinations whether each agreement it makes for disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor.” See Changes in Financial Management of Sponsored Projects Presentation 2 (12/14/2014) for additional information.
 
Two documents have been developed to help determine whether a subaward (subcontract) or a fee-for-service/procurement contract is more appropriate. The Statement of Work (SOW) Template assures that there is a complete description of the work to be performed.  The Third Party Agreement Determination Form, in combination with the SOW, can then be used to determine (and document consideration of) the appropriate type of agreement.  To request OSP to disburse federal funds awarded after December 26, 2014 as a subaward, send a copy of the completed Third Party Agreement Determination Form, the SOW, and all other Subaward Required Documents (per subaward) to osp@uab.edu. NOTE: The UAB PI and OSP Assigned Number must be included in the email subject line and all documents completed and included in order for the OSP to accept the submission as complete.  If you determine the disbursement should be as a contract (fee-for-service or procurement) include the SOW and Third Party Agreement Determination Form with the other documents you send to University Contracts.
 
Effective April 9, 2015, you will be asked to complete the Third Party Agreement Determination Form for any outstanding subawards or subaward requests for any post UG awards received by UAB. If you anticipate or are notified that an award is forthcoming that included a third party in the role of subrecipient you may expedite the process by reviewing the SOW and completing the Form appropriately. Going forward the SOW Template and Form should be used for any subrecipient at preparation of an application or submission in order to determine the appropriate role and costs for the subrecipient.

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