Before including a subaward in a proposal, you, as the principal investigator (PI) for the project, are required to determine whether the other institution is best classified as a subrecipient or as a contractor.

Once you have determined that a collaborating institution is a subrecipient, you will need to include additional materials to accompany the proposal. Depending upon the sponsor’s requirements, some of this information may be required in the full proposal submitted to the sponsor, while some of this information is for Brown’s records. The sponsor’s submission guidelines will provide the best reference to determine whether these documents will be submitted with the full proposal.

Letter of Intent

A letter of intent from the collaborating institution is required. This letter must do the following:

• State the collaborating institution’s intent to accomplish the work as outlined in the scope of work
• Identify the project title, period of performance and funds requested
• Include the language: "By signing below, Subrecipient Institution certifies that the appropriate programmatic and administrative personnel involved in this grant application at this organization are aware of the agency’s consortium agreement policy and are prepared to establish the necessary inter-organizational agreement(s) consistent with that policy," or similar language
• Be signed by the authorized organization representative for the subrecipient institution

Subaward Scope of Work 

A subaward scope of work details the technical and programmatic work to be accomplished by the subrecipient. The scope of work should clearly identify each of the subrecipient’s responsibilities. Your review of the subrecipient’s technical progress will be based on the scope of work, so the scope of work should provide sufficient specificity to allow you to hold the subrecipient accountable to performance of specific project components.

Please note that the scope of work will be published in a public database, viewable at usaspending.gov, in accordance with the Federal Funding Accountability and Transparency Act and should not include any proprietary or confidential information.

Subaward Budget 

A subaward budget should include detailed subrecipient costs associated with the completion of the subaward scope of work. The subaward budget should identify direct costs and itemize such costs by major cost categories, such as salary, fringe benefits, equipment, travel, etc. If the sponsor’s proposal guidelines allow for subaward indirect costs, then the subaward budget may also include indirect costs. 

To include indirect costs, the subrecipient must provide a copy of its current negotiated indirect cost rate agreement with the federal government or other documentation to support the indirect cost rate request. Unless the sponsor limits the recovery of indirect costs, the University may accept the rates established in the subrecipient’s federally negotiated indirect cost rate agreement.

Subaward Budget Justification

A budget justification providing the narrative description of the costs identified in the detailed budget is required. The subaward budget justification should identify the specific costs associated with each direct cost category. It should also provide a narrative description of the cost to justify and support the necessity of these costs for the completion of the subaward scope of work.

Other Documentation

In accordance with the sponsor’s proposal guidelines, if additional subaward documentation is required, these should be included as part of the full proposal submission. An example of other documentation that is required includes foreign component information if the subrecipient is a foreign entity.

If the prime sponsor of the award is the National Science Foundation (NSF), National Aeronautics and Space Administration (NASA) or Public Health Services (PHS) — including the National Institutes of Health (NIH) — or, if the prime sponsor has adopted the PHS conflict of interest regulations, then the subrecipient must either certify that they are following a financial conflict of interest (FCOI) policy that complies with the prime sponsor’s conflict of interest policy or agree that their researchers will follow Brown’s FCOI policy.

The subrecipient institution provides a completed FCOI Subrecipient Certification Form for inclusion in Brown’s proposal documents. 

If the prime sponsor of the award has a FCOI policy, and the subrecipient institution indicates that its researchers will follow Brown’s policy, then each subrecipient investigator is required to complete the University’s FCOI training and submit a completed copy of the Non-Brown University Investigator FCOI Disclosure Form. Research Subcontracting will coordinate with the Office of Research Integrity Conflict of Interest team to register the subrecipient investigator for the University’s FCOI training.

If the proposed subrecipient institution is a foreign organization, and it is the first time that the University has collaborated with that institution, the Sponsored Projects team strongly recommends that the PI/PD or department administrator contact the subrecipient organization at the time of proposal submission to start obtaining the required subrecipient monitoring documentation as early in the process as possible. The lead time for foreign organizations to provide this documentation and to complete SAM.gov registration for a Unique Entity Identifier (UEI) can be significant.