Title
Office of Sponsored Programs- 500.11 - Outgoing Subrecipient Agreements
Purpose
This standard is to establish the methods and means the University uses to establish Subrecipient Agreements. These agreements are legally binding and constitute the method to enforce the requirements of collaborative relationships with other institutions.
Policy Statement
Subrecipients are collaborating institutions that participate on sponsored projects received by a different institution known as the Pass-through Entity. The University serves as the Pass-through Entity on all Outgoing Subrecipient Agreements. The working relationship between the Pass-through Entity and a collaborator is established through a formal agreement. This Subrecipient Agreement is legally binding and details the roles and responsibilities of both parties. The Office of Sponsored Programs (OSP) is responsible for issuing outgoing subagreements for sponsored programs.
This differs from work with a contractor (suppliers) who only provide goods or services. A Subrecipient completes work that influences a project programmatically for a significant portion of the work.
I. Subrecipients Versus Contractor
Subrecipients have substantive, programmatic participation in a sponsored project. This is most easily identified by their involvement in designing, directing, and conducting the research as proposed. Subrecipient identifies a representative to manage the project at their institution and they are considered key personnel on the University’s project. They are given some flexibility to conduct their portion of the research.
Contractors, also known as suppliers, are not directly involved with the scientific direction of the project. They are providing goods or services in a consistent manner for all of their business customers. There is also no independence in how they complete the activities being purchased.
II. Requirements of Subrecipient Agreements
Period of Performance
The Subrecipient Agreement must clearly state the period performance for the collaboration. Agreements may be issued for periods shorter than the project’s performance period as issued to the University by the sponsor. However, it cannot extend past the University’s performance period.
Terms & Conditions
Any agreement must include the requirements placed on the Pass-through Entity by the sponsor or the University. The sponsor requirements applied to a project received by University regularly apply to the subrecipient.
Statement of Work
Subrecipient Agreements are required to have a detailed description of what work will be completed by the subrecipient institution. This includes details on tasks, scheduling, and how they will actively collaborate with the University.
Budget & Budget Justification
The University requires all Subrecipient Agreements to include a subrecipient budget detailing the amount of expenses and a budget justification that explains the necessity of those expenses. The subrecipient’s indirect cost rate agreement is also collected, if applicable. These are used to determine the amount of funds that will be provided to the subrecipient under the Agreement.
Other Sponsor Requirements
Particular sponsors may require additional information for Subrecipient Agreements. It is important to always consult the sponsor terms and conditions and any other regulations that apply. For additional guidance, contact your OSP Contracting Officer (CO).
III. Issuing Subrecipient Agreements
Subrecipient Agreements are created by OSP in conjunction with the administrating department. Agreements are created using the relevant documentation identified by the administrating department. This is commonly the subrecipient information included in the proposal or what is revised at time of the award. If there are no further changes needed, a draft agreement is provided to the Subrecipient for review and execution. The partially executed agreement is returned to the University for signature. Once the agreement is fully executed, the Subrecipient Agreement is considered finalized and any internal financial setup is completed.
IV. Roles and Responsibilities
Roles and Responsibilities Table
Description |
PI |
DA |
OSP |
Determine the need for a Subrecipient |
|
|
|
Identification and selection of Subrecipient |
● |
|
|
Collection of Subrecipient Documentation for Proposals and Agreements |
|
● |
|
Review of Subrecipient Documentation for Proposal and Agreements |
|
|
● |
Review eligibility of Subrecipient Institution and Project Personnel |
|
|
● |
Obtain Sponsor approval to work with Subrecipient |
|
|
● |
Administer a Subrecipient Agreement from creation through execution |
|
|
● |
Executes Subrecipient Agreements, Modifications, and Amendments |
|
|
● |
Monitoring programmatic activities of the Subrecipient |
● |
|
|
Monitoring the Subrecipient Expenditures |
● |
● |
|
Approval of Subrecipient Invoices |
● |
|
|
Processing Subrecipient Invoices for Payment |
|
● |
|
Reviewing and approving Subrecipient Invoices for Payment |
|
|
● |
Notifying OSP of any changes needed to the Subrecipient Agreement |
● |
● |
|
Obtaining Subrecipient Documentation for Progress Reports |
● |
● |
|
Issuing Modifications and Amendments to Subrecipient Agreements |
|
|
● |
Definitions
Subrecipient:
A subrecipient is an institution that collaborates with the University to carry out part of a sponsored project. They may receive a legal agreement from the University to cover these duties or receive an award directly from the sponsor.
Contractor:
An entity that receives a contract for the purposes of providing goods or services through their normal business operations on a competitive basis. These are ancillary to the operation of the sponsored project and do not involve programmatic input on how the project is conducted. This is also referred to as a supplier.
Pass-through Entity:
The institution that provides a subrecipient agreement to another collaborating institution to complete a portion of a sponsored project. The University serves as the Pass-through Entity for Outgoing Subrecipient Agreements created by OSP.
Subaward:
A type of subrecipient agreement issued under a grant or cooperative agreement.
Subcontract:
A type of subrecipient agreement issued under a contract.
Related Requirements
Contact Information
For questions regarding this operating standard and its related procedure, please contact SponsoredPrograms@unc.edu.
For questions regarding Pre-Award management or Post-Award administration, please contact the assigned Sponsored Projects Specialist (SPS).
For invoicing, reporting and other financial matters, please contact the assigned Sponsored Projects Accountant. OSP Staff assignments are found in RAMSeS or on the OSP website.
History
History Table
Date |
Description |
07/01/2022 |
Revised to reflect new office name. |
02/14/2022 |
Removing Subrecipient Commitment Form from requirements |
10/27/2020 |
Updated 'vendor' to 'supplier' to reflect change in financial system. |
05/15/2018 |
Revised to coincide with the release of the new OSP Website. |
02/17/2010 |
Revised to specifically address A-110 procurement standards. |
The operating standards in the Office of Sponsored Programs Operating Standards & Procedures Manual supersede any OSP operating standards, procedures and appendices previously included in the University Business Manual, a publication of UNC-Chapel Hill’s Division of Finance.