GIM 7

Sponsored Programs Subaward Policy

UNIVERSITY OF WASHINGTON

Office of Research
Office of Sponsored Programs

GRANTS INFORMATION MEMORANDUM 7

August 24, 2012

Purpose

This GIM sets out the policy and outlines procedures for the administration of subawards issued by the University under a prime agreement (contract, grant or cooperative agreement) awarded to the University.

When the University issues a subaward, it maintains responsibility to the prime sponsor for managing the funds and ensuring performance meets the expectations under the prime agreement. This policy and associated procedures are developed with the intent to manage risk of subaward issuance, set out responsibilities related to administering and monitoring subawards, and ensure compliance with federal, state and local laws that affect the performance under, and the administration of, subawards.

Background

A subaward is a special type of agreement that differs in several respects from those for the more standardized procurement of goods and services from commercial vendors. The distinction between a subrecipient and a vendor is based on the federal guidance found within OMB Circular A-133, Attachment A.

The issuance of a contract to procure goods and services is managed by University Procurement Services whereas a subaward is issued by the Office of Sponsored Programs (OSP).

The prime sponsor's award to the University usually includes specific authorization for the subaward. Occasionally, the need for a subrecipient's collaboration develops after an award has been made to the University. Under those circumstances, most sponsor policies require that the University obtain sponsor approval of the subaward before it is entered into by both parties.

Persons / Offices Affected

UW Principal Investigators and Departments, Subrecipients, Office of Sponsored Programs, Payables Administration, and Grant and Contract Accounting.

University Policy

To ensure compliance with the prime sponsor funding, regardless of the grant or contract fund source, the Office of Sponsored Programs (OSP) prepares and administers subawards in accordance with Federal policy found in OMB Circulars A-110, A-21, and A-133 and sponsor policies found in the prime award to the University.

Subawards cannot be issued until the University has received and processed the prime award (e.g. the prime funding is in a "processed" status and has received a budget number) and the related purchase requisition, subrecipient supporting documents, and other information requested from the subrecipient, are provided to OSP.

Subawards may only be issued on behalf of the University by the institutional officials with delegated signature authority within the Office of Sponsored Programs.

Procedures and Guidance

Responsibilities

Office of Sponsored Programs (OSP)
Principal Investigator

Definitions

Originating sponsor:
The sponsor to the University of Washington.
Prime institution:
Institution which received the sponsored agreement directly from the sponsor.
Purchase requisition:
An order initiated by a campus department to purchase goods and services. The requisition provides details to describe a needed purchase.
Subaward:
Binding legal contract between UW and another institution or entity regarding completion of part of a sponsored program.
Subawardee, subrecipient:
Institution receiving a subaward or subcontract from prime institution.

Other Related Resources

SubjectDocument
Screening of subrecipient entities and key personnel Excluded Parties List System (EPLS)
Ordering a subaward via the procurement system University Purchasing and Accounts Payable Online System (PAS)
Monitoring the prime sponsor budget number MyFinancial Desktop
Federal requirements to report subrecipient information Federal Funding Accountability and Transparency Act (FFATA)

Contacts

SubjectContactEmailPhone
Proposal preparationOSPosp@uw.edu206-543-4043
Issuance of subawardOSP Subawards Teamospsubs@uw.edu206-543-4043
Procurement of goods or servicesUniversity Procurement Servicespcshelp@uw.edu206-543-4500

Content Creator

Office of Sponsored Programs