The JHURA Subawards team must always operate within the parameters of: Federal, State and Local laws governing Subawards, Unique Agency Regulations, Prime Award terms and JHU Policy.
On December 26, 2014, the Office of Management and Budget combined several OMB Circulars into one guiding document called the Uniform Guidance (or “UG”), which can be found at 2 CFR Part 200. Each federal grant making agency (e.g. NSF, NIH, DOD, USAID) issued its own implementing regulations that are all, unfortunately, slightly different. If you have questions as to how a particular funding agency implemented the Uniform Guidance, please see the reference guide or contact JHURA.
The UG impacted Subawards in multiple ways including: More concretely setting out the differences between a subrecipient and a contractor; for subawards under a prime award other than HHS/NIH, a fixed price subaward can only be issued for up to $150,000 with permission from the sponsor; stricter requirements for Subrecipient monitoring.
For additional information, please read the most recent NIH Grants Policy Statement.
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