A prime organization with a sponsored grant or contract may allocate a portion of the scope of work to another organization (subrecipient) to complete. A subagreement will be generated to obligate funding support and the sub-portion of the scope of work to the subrecipient by either a subaward or subcontract. Determination on which subagreement is utilized is dependent on whether the Sponsor award is a grant or contract. For information on subcontracts issued under Federal contracts, please visit the Federal contract page.
Sponsor guidelines should be reviewed to ensure the appropriate documents are requested and collected from the subrecipient. All subrecipient documents will need to be attached to the SPS Internal Documents section of SPS for ORA review.
Documents needed to issue a new sub:
- PHS 398 Face Page
- Subrecipient FCOI Certification Form - Award (for PHS and PHS+ agencies only)
- First Year Detailed Budget or SF424 R&R Subagreement Budget
- Budget Justification
- PHS 398 Checklist
- Statement of work
Documents needed for amending a sub:
- PHS 2590
- Subrecipient FCOI Certification Form - Award (for PHS and PHS+ agencies only) (if new budget period and NCE)
- Current year's budget
- Statement of Work (if changed)
Award Activation Stage
Steps to follow to initiate the issuance of a subaward or amendment upon receipt of award notification:
- Ensure Duke's award is in "Awarded" state in SPS
- If the funds are not available in the contractual G/L line in SAP, route a rebudget to add funds to the subaward fund code. Invoices will not be paid if funds are not in the code.
- Obtain a separate fund code for each subaward (not needed for capitation agreements)
- Complete and submit the electronic Subagreement Initiation Request (SIR) .
What happens after the Subagreement Initiation Request webform is submitted?
If your request contains all of the necessary documentation, an agreement manager will draft the subaward and send an unsigned, electronic copy to the subrecipient. If the subrecipient requests changes that are programmatic in nature, we may consult with the point of contact indicated on the SIR. Once the subrecipient signs and returns the partially executed (PE) subaward, we will countersign to fully execute (FE) the subaward. The fully executed subaward will be returned to the subrecipient electronically with a courtesy copy to the point of contact indicated on the SIR. If the subrecipient requires a hard copy, the agreement manager will notify the point of contact on the SIR once the original has been signed. It will be the department's responsibility to return the fully-executed hard copy to the subrecipient.
When a subagreement is not approved at the initial application stage, written approval may be required from the sponsor. Refer to award notice and sponsor's policies for prior approval requirements. Justification to the sponsor will need to sufficiently indicate why the scope of work will need a subagreement as well as how the current awarded funds will be redistributed to accommodate the subrecipient's costs. Please work with the your assigned ORA Research Administrator to submit a prior approval request to the sponsor, if necessary.
Agreements issued under federal funding sources are subject to GAP 200.280 Subrecipient Monitoring. The agreement manager will perform a risk assessment before issuing the subaward and may contact the SIR initiator if any issues arise during the assessment. Additional terms may be added to the agreement based on the results of the assessment.
Financial Conflict of Interest for Subrecipients
The U.S. Department of Health and Human Services (HHS) has issued a final rule in the Federal Register that amends the Public Health Service (PHS) regulations on Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought (42 C.F.R. Part 50, Subpart F) and Responsible Prospective Contractors (45 C.F.R. Part 94). An Institution applying for or receiving PHS funding from a grant, cooperative agreement, or contract must be in compliance with all of the revised regulatory requirements.
PHS and PHS + agencies following this policy are located on the FDP webpage.
Prior to issuing a subaward, the agreement manager must have the Subrecipient FCOI Disclosure Form - Award. This form requires the subrecipient to disclose any financial conflicts prior to expenditure of funds. If subrecipients are utilizing Duke's FCOI policy, or have any disclosures, the subaward will not be signed at Duke until the Research Integrity Office has cleared the subrecipient.
For questions about the Duke policy for FCOI, please contact RIO at firstname.lastname@example.org or 919-684-3121.
Vendor Agreements (RSSAs)
Vendors, who provide services that are ancillary to the project, are handled through Duke's Procurement Services office. As vendors provide a service to the sponsored project, they are not considered to be a subrecipient as their role does NOT provide any programmatic decision-making. Therefore, costs associated to a vendor would fall under an Other Direct Cost budget category and would be charged indirect (F&A) costs as any other direct cost line item within an application.