compliance: Subrecipient/Contractor

Collaborations with other researchers at other institutions (Subawards)

Many times, faculty work with colleagues at other institutions to accomplish their research and may want to have the collaborator(s) complete a portion of the work for the grant project.  Collaborative arrangements can be formalized in the form of a subaward or subcontract, depending on the substance of the agreement. The development of these relationships begins at the pre-award stage.  Regardless of the type of relationship, the proposed costs must be incorporated into the overall budget that will be submitted on behalf of the PI/PD by EWU.

Pre-award staff will guide this process. Once a determination is made as to the type of relationship, certain information will be required prior to submission:

For subawards, information will include:

  • a subrecipient commitment form
  • scope or statement of work deliverables
  • budget
  • budget narrative
  • an applicable indirect cost rate agreement.

Subcontracts, which can include contracts for professional services,  will require:

  • a letter stating time commitment
  • scope of services
  • rate of compensation
  • timeframe of the work

Irrespective of the type of relationship,  EWU is ultimately responsible for the oversight and management of all arrangements to ensure compliance. The type of oversight needed is determined by the type of relationship:

A subrecipient (the recipient of the subaward) is responsible for completing some portion of the sponsored project’s work in and is subject to the laws, regulations, and terms and conditions that govern the prime award that provides the funding to the university.

A subcontractor (the recipient of the subcontract)  generally provides goods or services that are ancillary to the project, which can include professional and consultant services to provide services that require specific skills.

Federal subawards are subject to the same grants management and compliance requirements as EWU (the pass-through entity), where contracts are not.

The chart below highlights the main differences between subaward and subcontracts:

An assistance relationshipA procurement relationship
Determines eligibility-risk assessment and is subject to subrecipient monitoringNormally operates within a competitive environment
Performance measured against federal program objectives Provides similar goods or services to many purchasers within normal business hours
Responsible for programmatic decision makingDoes not make programmatic decisions
Adheres to applicable federal program requirementsAdheres to the terms and conditions of a contract to ensure allowability
Uses funds to carry out a program for public purpose specified by the statute that the grant abides byUses funds to carry out services needed to help EWU carry out the program or project under the federal award
Provides goods and services that are ancillary to the program
Subject to federal program compliance requirements of the federal program Not subject to compliance requirements of the federal program