When Stanford is a Subrecipient

At Proposal

When Stanford is being incorporated into another institution's proposal as a subrecipient the Stanford subaward proposal must be reviewed and institutionally endorsed by Stanford like any other sponsored project proposal.   Stanford subaward proposals should always be reviewed and institutionally endorsed before being submitted to the other institution aka the pass-through-entity (PTE).

For proposals submitted through the School of Medicine’s Research Management Group (RMG), the PI/ department should within the Stanford Electronic Research Administration (SeRA) system complete a Proposal Intake Form (PIF) in SeRA and submit to RMG for intake and processing (recommended at least 30 days in advance of the sponsor deadline). The Research Process Manager (RPM) will then follow up with a draft budget, internal deadlines, and proposal guidance as needed.

Note: the SoM PIF process excludes SoM postdoc fellowships and industry sponsored clinical trials.

For proposals submitted through the Office of Sponsored Research, the PI/ department should within the Stanford Electronic Research Administration (SeRA) system complete a Proposal Development Routing Form (PDRF) in SeRA and submit to OSR for intake and processing in accordance with the Stanford internal proposal deadline policy.

• When Stanford will be a subrecipient the selected agreement type on the associated SeRA PDRF should be subcontract.
• Attach to the SeRA PDRF both the program guidelines for the prime proposal as well as any instructions/guidelines provided by the PTE in addition to all other standard PDRF attachments.

See the SeRA Proposal Development & Routing page for step-by-step instructions for initiating and completing either the PIF or PDRF.

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? 

For Stanford faculty providing letters of support as part of proposals to the NIH 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.

At the Time of Award

The Office of Sponsored Research is the institutional office that negotiates and accepts all incoming subawards at Stanford. 

View who will negotiate and accept your incoming subaward via the OSR Institutional Official Contacts and Department Assignments

When Stanford is a subrecipient the pass-through-entity (PTE) may request that Stanford complete the Federal Demonstration Partnership (FDP) Attachment 3B to provide subrecipient contact information.  Below is a sample FDP Attachment 3B for Stanford.

Stanford Sample FDP Attachment 3B

The PTE may also request certification forms regarding Stanford’s single audit status. These forms can be sent to osr_intake@stanford.edu for completion, authorized signature, and return to the PTE.  For quick reference, most institutional information requested by the PTE can be found on the DoResearch Institutional Facts page.

If you have questions regarding the Attachment 3B or PTE audit certification forms, please contact your OSR Contract and Grant Officer. 

OSR Institutional Official Contact and Department Assignments

Project Management

Terms and conditions 

When Stanford is a subrecipient the award agreement we receive from the PTA may include terms and conditions that are more restrictive than the prime agreement from the prime sponsor.  It is critically important for research administrators managing incoming subawards to follow the order of precedence of the terms for the award.

Prior Approval Requests

When Stanford is a subrecipient, any sponsor prior approval requests, including but not limited to any significant reduction of PI and/or senior key personnel effort, should be initiated through the appropriate SeRA Central Office Request and ultimately submitted from a Stanford Institutional Official to a business official at the PTE and should NOT be submitted directly to the prime sponsor.

Invoicing

Incoming subawards are invoiced and collected by the ORA Sponsored Receivables Management (SRM) Team. However, some PTEs request additional documentation of expenses and/or reporting to accompany invoices. When project invoicing requires this type of documentation, strong communication between ORA SRM and the department is necessary to ensure the requirements are met.

If project invoicing is based upon deliverables, it is critically important that the department provide ORA SRM notification when a deliverable or milestone is met so invoicing can be completed. Establishing timelines and check-ins on progress may be helpful to stay on track.

Closeout

Incoming subawards are closed out at Stanford very similar to other sponsored projects.  The managing department must ensure all Stanford expenditures have been incurred so that Stanford can accurately report to the sponsor and conclude any final sponsor billing.  This includes PI & Key Personnel effort having been appropriately charged to the project in accordance with the award’s terms & conditions. 

A PTE in their subaward to Stanford may…

• Specify a shorter closeout timeline than the standard 120 days we have for awards made directly from most sponsors (refer to your subaward terms and conditions) or…
• Give Stanford an earlier end date or shorter final period of performance than the prime award

Either of these options may occur in order to allow the PTE sufficient time to collect all of Stanford’s final expenditure and technical information to incorporate into their prime award closeout.

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