Proposing a Subaward
Proposing a Project with Subawards
Once the potential subrecipient is identified to support the objectives of a proposed sponsored research project, and it is determined that a subaward is the appropriate mechanism, the PI assisted by the department administrator obtains the subrecipient proposal elements from their subrecipient.
The proposal should be compiled in the format required by the sponsor and Stanford, then forwarded to the institutional official for review. The proposal must include the following elements for each named subrecipient to be endorsed by institutional official.
- The subrecipient's statement of work (SOW), including a clear description of the work to be performed, proposed timelines, and deliverables. The SOW should be detailed to ensure expectations are clear and can be enforced in case of disagreement between Stanford and the subrecipient.
- The subrecipient's budget and budget justification, including the subrecipient's direct and indirect costs, calculated using both the subrecipient's F&A and fringe benefit rates, and verifying any committed cost sharing.
- The Subrecipient Commitment Form (OSR Form 33) completed and signed by the subrecipient's institutional official.
- (Federal Contracts Only) A Fair and Reasonable Cost Analysis & Sole Source Justification (OSR Form 45) if the funding mechanism is known to be a Federal contract at time of proposal. The PI's signature on this form certifies s/he has selected the subrecipient in accordance with Stanford policy, and determined their costs are reasonable with respect to the proposed SOW. In addition, the PI certifies s/he has reviewed the subrecipient's proposed budget to ensure all proposed costs are allowable under the sponsor's anticipated terms and conditions. PIs are responsible for working with their subrecipients to modify proposed budgets to bring them into conformance.
- Additional elements which may be required by Stanford's sponsor.
On very rare occasions, a PI may recognize the need for outside involvement on a project but is either unable to identify the best subrecipient by the time of proposal submission. In these instances, proposals may be submitted with a subrecipient To Be Named.
NIH Subaward/Consortium Lab Notebook Requirements for Foreign Entities
Effective January 2024, the National Institutes of Health updated the requirements for data in support of technical progress as reported in the project RPPRs for foreign subrecipients. NIH Notice NOT-OD-23-182 provides the final guidance for this updated requirement. The additional guidance provided by NIH affects proposal documentation, the written subaward agreement, and the monitoring activities of the Stanford PI.
- NIH expects recipients to ask potential subrecipients at the application stage to submit language in their letters of support indicating 1) their awareness of these requirements and 2) the subrecipient’s willingness to abide by all requirements should an award be issued.
- For foreign subrecipients, a provision requiring the foreign subrecipient to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic.
What does this mean for Stanford Investigators and Departmental Administrators at the time of proposal?
To meet the NIH requirements, Stanford has implemented the following:
- Stanford's Subrecipient Statement of Collaborative Intent (OSR Form 33) includes the required proposal certification. A complete and institutionally endorsed OSR Form 33 is required to be obtained from each proposed subrecipient on NIH proposals prior to proposal submission to the NIH.
- Letters of support provided by subrecipients proposed on Stanford NIH proposals must include a statement of their awareness of the requirements in NIH Grants Policy Statement (GPS) Section 15.2 and NOT-OD-23-182 , and their intent to abide by those requirements should an award be issued.
- For Stanford faculty providing letters of support where Stanford is the subrecipient, we recommend including the following language in the letter.
- Stanford is aware of the NIH requirements in the NIH Grants Policy Statement, Section 15.2, and in NOT-OD-23-182, and is willing to abide by all requirements should an award be issued.
Integrating the Subrecipient's Proposal into Stanford's Proposal
The PI, assisted by the administrator, integrates the subrecipient’s statement of work into the proposal and includes the full amount of the subrecipient’s budget (including the subrecipient’s F&A) as a direct cost line item in the Stanford budget. The subrecipient’s proposed costs must be separate from Stanford’s costs.
When calculating Stanford’s budget, it is important to apply the F&A Stanford will collect for administering the subaward based on the sponsor’s inclusion/exclusion criteria. While the federal government includes the first $25,000 in its F&A base, other sponsors may have different criteria.
- Modified Total Direct Cost (MTDC) Base: Stanford’s indirect costs (F&A) are applied to the first $25,000 of each competitive segment of each subaward. (Typical of federal awards).
- Total Direct Cost (TDC) Base: Stanford charges indirect costs on the whole subaward amount. (Typical to foundation or other non-fed sponsors).
Subrecipient Proposal Review and Submission by Stanford
At the time of proposal review & submission if submitted in accordance with Stanford's Proposal Policy, the institutional official will do the following:
- Review the Statement of Collaborative Intent (OSR Form 33)
- Review the subrecipient’s scope of work to verify that a subaward is the appropriate vehicle to fund the work
- Review the subrecipient's budget and budget justification
- Review the proposal for compliance with Stanford and sponsor policy
- Submit the full proposal to the sponsor for consideration
*Initiating an Unanticipated Subaward after a Proposal Is Submitted
If a subrecipient was not included as part of the proposal documentation, the sponsor may require prior approval to add a new subrecipient to the sponsored project. All subaward paperwork should be completed at the time the subrecipient is identified.
- If the subaward is under a grant, the prime sponsor award terms and conditions may require prior approval or notification for adding a new subrecipient. Read the terms and conditions carefully and confer with your OSR/RMG official if you need guidance. Be prepared to wait at least 30 days for a response from the sponsor for prior approval of the new subrecipient.
- Use the Central Office Request Form found in SeRA to seek sponsor approval for new subaward if approval is required.
- If a subaward is under a federal contract, the sponsor may require Stanford to obtain written approval or notification to enter into the subaward even if the sponsor approved the subrecipient at the proposal review and acceptance stage. A federal sponsor may require: a detailed written cost analysis of the subrecipient’s proposal, a certificate of cost and pricing data together with a sole source justification (form 45) and a small business subcontracting plan (FAR 52.219-9).