A subaward/subcontract begins in the proposal development phase of an award. Verification from the subrecipient must be obtained through completion of the Subrecipient Commitment Form. This form also confirms that the subrecipient has the basic policies and procedures in place to manage federal funds. In addition to the Commitment Form, the subrecipient must also provide Georgia Southern a statement of work, budget, and other necessary documentation.
Why am I being asked to complete this form?
The Subrecipient Commitment Form is designed to collect information about each subrecipient named in a proposal at the proposal stage. The information provided on the subrecipient Commitment Form helps the ORSSP verify the eligibility of the subrecipient and that the information about the subrecipient contained in the proposal has been approved by the subrecipient’s Authorized Organizational Representative (AOR).
If the proposal is funded, the information on the subrecipient Commitment Form helps ORSSP conduct a risk assessment of the subrecipient prior to entering into an agreement. The information on the subrecipient Commitment Form is considered valid if signed by the subrecipient’s AOR within 12 months of the date of the AOR’s signature.
Note: The final determination on the type of relationship involved (subrecipient vs. contractor) and the acceptability and of any proposed subrecipient will be made after (a) the award has been received, (b) the Principal Investigator (PI) has requested that an agreement be established, (c) ORSSP has determined that the scope of work is appropriate for a subrecipient, and (d) a risk assessment of the proposed subrecipient has been conducted. Subawards will not be issued to subrecipients that pose an unacceptable risk to the University.
Before Completing the Subrecipient Commitment Form
Organizations that meet the criteria of a subrecipient will be expected to:
- Conform to all of the compliance requirements from the prime award that are pertinent to the subrecipient, e.g., effort reporting on federal awards.
- Provide a complete copy of the subrecipient’s most recent audit report, or the URL link to a complete copy, before a subagreement can be established.
DO NOT ACCEPT THE ROLE OF A SUBRECIPIENT IF YOUR ORGANIZATION IS NOT PREPARED TO ACCEPT SUCH TERMS.
Each subcontractor must have their own itemized budget including salaries, fringe benefits, equipment, travel, supplies, other direct costs, indirect costs and cost sharing; they must also provide a description of the scope of work to be provided the project.
Subaward budgets should use the F&A rate set by the subcontractor’s institution and a copy of that rate agreement should be provided.
Any subcontracts from other universities must be routed through the subcontracting institution’s approval process to obtain the necessary approvals prior to routing the proposal through Georgia Southern University.
A completed form indicating institutional concurrence for the proposed activity for each subrecipient must accompany the proposal. If the subrecipient is a member of the FDP Expanded Clearinghouse, use the FDP Letter of Intent. If not a member, use the Subrecipient Commitment Form: Non-FDP. The appropriate form, when signed by an authorized official of the subrecipient organization, indicates compliance within all necessary areas and institutional concurrence with the submission.
The list of FDP Expanded Clearinghouse members is available at https://fdpclearinghouse.org/organizations.
During the Award Negotiation Phase
After the federal agency has issued a notice of award to Georgia Southern University Research and Service foundation, Inc., the University is responsible for initiating subaward agreement(s) with the proposed subrecipient(s). This process is carried out by the Grant Coordinators in the Office of Research and Sponsored Programs (ORSSP). During this phase, a risk assessment of the subrecipient’s compliance process and eligibility to receive federal funds is performed.
Once the subward/subcontract has been initiated, the Principle Investigator (PI) should coordinate with the Office of Research Accounting (ORA) to encumber the funding the subaward/subcontract and obtain a Purchase Order for future payment to the subawardee. The ORSSP, ORA, and the PI are jointly responsible for regular monitoring of the subaward throughout the life of the award. The purpose of monitoring is to 1) ensure federal funds are spent in compliance with the applicable laws, regulations and provisions, and 2) ensure performance goals are met.
For more information and detail on the procedures, please review the University Sub-Awardees/Consultants/Vendors policy.
|VENDOR (CONTRACTOR)||EXTERNAL CONSULTANT||INTRA-UNIVERSITY CONSULTANT|
|An entity that has agreed |
to work in collaboration with
the PI to perform a substantive
portion of the programmatic
effort on an award.
|An individual, business, or other entity which supplies products or services to the University.||An individual or business whose expertise is required to perform the project. Services are temporary and special or highly technical.||A Georgia Southern University employee whose expertise is temporarily required to perform the project.|
|Works collaboratively with the PI as a co-investigator at another|
entity to which funds are being passed;
designated senior/key personnel in the proposal-may be a Co-PI,
shares responsibility for end results
Has authority to make administrative and programmatic decisions and to control the method and results of work
Has responsibility to meet all applicable sponsor requirements
Has performance measured against meeting the program objectives
Uses sponsor funds to carry out a program rather than provide a good or a service
Services are complex and require a scope of work and budget, billing requirements, and a deliverable schedule
Statement of work may represent an intellectually significant portion of the programmatic decision making
Work results may involve intellectual property and/or may lead to publications, presentations/dissemination such as at professional conferences
Needs animal and/or human subjects approvals for its independent portion of the work
F&A costs apply only to the first $25,000 of the award
|Provides similar goods or services to different purchasers, as part of normal business operations; goods/services are ancillary to the program|
Does not make program decisions or take actions that impact a program's overall success or failure
Is not subject to sponsor compliance regulations
Competes with comparable entities to provide the same goods and/or services
Is not responsible for research results
There is no scope of work
Goods and services are billed according to established rates
The goods and services are secondary to the central purpose of the project
No potential for patentable or copyrightable technology to be created through project from activities of the entity
Performs services only (no analysis or discretionary judgment)
No one individual providing goods and services is identified
F&A costs apply to the entire figure, regardless of total (other direct costs in the budget)
|An individual or business outside the project who confers with the PI regarding research objectives|
Does not develop the objectives of the project
Is not responsible for the overall outcome of the project
Is not responsible in designing or developing the research
Is not responsible for conducting the research
Is not responsible for reporting the research
Is not essential toward the shape, direction, and completion of the project
Receives a fee for their services not a salary
Provides similar services to other organizations
Does not serve as senior personnel – e.g., Co-Investigator, Principal Investigator, etc
Will not use university resources. Provides its own work area, tools, materials, and supplies
GS defines the scope of work
Consultant determines how to accomplish the work
Is not considered an employee of the University and therefore is not eligible for worker compensation, liability coverage, or unemployment
Payment is based upon completion of specific work, rather than time worked
|Is above and beyond the employee's regular duties
Services are provided outside normal work hours
Is not named as an investigator on the project
Is not an employee of the project
Is performed for a department, center, or academic unit other than the employee's assigned department
Is performed at a remote location
Last updated: 3/2/2020