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Subaward Issuance

Required documents and information to initiate a subaward

When the prime award is made to the University and accepted by OSP, Grant and Contract Accounting (GCA) assigns a budget number and the PI is notified.

To avoid unnecessary delays, the PI or designated staff person in the UW department should enter an on-line Purchase Requisition in the University Purchasing and Accounts Payable Online System (PAS) at the time the budget number is issued. This is then directed via Purchasing's Buyer Assignment unit to OSP. All supporting documentation (e.g. current budget, budget justification and scope of work of the subrecipient) must be provided to OSP, either along with the requisition via the Requisition Document Attachment system (requires UWNETID) or to the OSP subaward team directly via If sent via e-mail, please include the Purchase Order (PO) Number.

The subaward team reviews the prime award, subrecipient documentation and prepares the subaward agreement. The subaward team may request additional information from the intended subrecipient such as:

Delay in receiving requested information will delay issuance of the subaward.

Issuance of the subaward

The University is a member of the Federal Demonstration Partnership (FDP), a program to streamline the operations of grants management between U.S. universities and certain federal agencies. Whenever possible, the University uses the Federal Demonstration Partnership (FDP) subaward template to transfer subaward funds to other FDP members.

Subawards are typically funded on an annual basis with renewals granted for additional time based on need and availability of prime award funding. Modifications may be made to subawards when circumstances require a change to the terms and conditions. Such modifications may be due to:

After the subaward is signed by OSP, it is sent electronically by email attachment to the subrecipient for review and execution. After the subrecipient returns the fully- executed agreement to OSP by email attachment, OSP encumbers the funds in ordered status in PAS, so that invoices from the subrecipient may be received and approved for payment.

Please note that splitting the cost of a subaward on multiple UW budget numbers is not allowed.

Subawards and FCOI

In addition to other sponsor requirements, subrecipients are required to comply with all financial conflict of interest (FCOI) rules and regulations set by sponsors, including the requirements of various agencies of the federal government.

Effective August 24, 2012, all recipients of federal PHS funding must be in compliance with revised FCOI rules and regulations consistent with the provisions of 42 CFR Part 50, Subpart F. Subrecipients will also be required to provide written, contractual FCOI assurances to the University of Washington prior to the release of any federal funding from any federal agency, including PHS. Such assurances will include representations that the subrecipient has adopted a FCOI policy that complies with all applicable federal FCOI rules and requirements.

As a matter of practice, departments and PIs are strongly encouraged to communicate with prospective subrecipients prior to the submission of proposals to confirm that the prospective subrecipient has an institutional policy that is compliant with federal and PHS funding requirements. The Federal Demonstration Partnership (FDP) has created a clearinghouse of institutions and entities that have attested that they are compliant with the revised PHS FCOI policy as of August 24, 2012. The purpose of this list is to allow prime awardees to quickly verify that its subrecipients will be compliant with the updated PHS FCOI policy requirements. Additionally, FDP has created a model FCOI policy that may be adopted by subrecipients who have not adopted their own compliant PHS FCOI policy. Tools are available on the NIH website to assist institutions with this process, including a “Checklist for Policy Development” and a FCOI tutorial.

As part of the revised PHS FCOI rules and the University of Washington’s own rules implementing the PHS FCOI rules, subrecipients must disclose to the University of Washington all of their investigators’ FCOIs. Such FCOIs are required to be managed during the life of the award and reported to the University of Washington. Additionally, subrecipients will be required to certify whether there have been any changes to the FCOI status of any of its investigators. Failure by a subrecipient to meet these requirements in a timely manner may result in suspension or termination of its subaward funding.