Outgoing Federal Subawards

Outgoing Federal Subawards

Office of Sponsored Programs Guidance Outgoing Federal Subawards

Outgoing Federal Subawards

When UAB is the prime recipient of a federally funded grant or contract, it may allocate a portion of the scope of work for the project to another organization (subrecipient). UAB will generate an outgoing federal subaward to the subrecipient organization detailing terms and conditions of the award including funding obligations and scope of work requirements.

The Federal Office of Management and Budget (OMB) has released guidance on Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (which may be called OMB Circular A-81, Uniform Guidance or Omni-Circular).

Per the new Uniform Guidance regulations, 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.”

In determining whether funds should be passed as a subaward or contract, “…the substance of the relationship is more important than the form of the agreement.”

Additional Information

Subrecipient Application Information

Two documents have been developed to help determine whether a subaward (subcontract) or a fee-for-service/procurement contract is more appropriate.

 

 

 

If the determination is made that the disbursement should be processed as a subaward, the PI should collect additional subrecipient application information including;

 

 

 

 NOTE: The Subrecipient Assurance Form - Project Specific (FDP Expanded Clearinghouse) form listed above is to be used when the institution is a participant in the Federal Demonstration Partnership (FDP) Expanded Clearinghouse.

Submission to OSP

To submit subward information to OSP, send a copy of the completed and signed Third Party Agreement Determination Form, the detailed subrecipient SOW, and all other subaward required documents to osp@uab.edu.

NOTE: The UAB PI and OSP Assigned Number should be included in the email subject line of the communication.

 

OSP Responsibilities

Validate Subrecipient Eligibility

  • Confirm subaward is allowed by sponsor
  • Investigate subrecipient’s eligibility status (e.g., not debarred, suspended, or delinquent on federal debt)
  • Confirm subrecipient vs. contractor (vendor) status
  • Review compliance information on Subrecipient Assurance Form (e.g., no involvement in lobbying, use of human/animal subjects)

Collect Risk Information/Manage Subrecipient Risk

  • Review subrecipient’s most recent A-133 / single audit (if applicable)
  • If A-133 / single audit not applicable:
    • Request/review Supplemental Financial Questionnaire
    • Request/review subrecipient’s most recent financial statement

Issue a management decision for any identified risks

Prepare Subaward Document

  • Flow down applicable terms and conditions from prime award
  • Determine type of subaward (cost reimbursement, fixed price, etc.)
  • Establish payment schedule (if applicable)
  • Establish time line for deliverables (if applicable)
  • Insert risk reduction clauses (if applicable)
  • Example:
    • Additional monitoring/reporting
    • Detailed invoices/backup receipts

Additional assurances

Issue, negotiate, and sign subaward on behalf of UAB.

Resources

Links