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School of Medicine Office of Research Administration

Outgoing Subawards

What is a Subaward?

A Subaward is an award provided by a pass-through entity [JHU] to a subrecipient for the subrecipient to carry out part of an award received by the pass-through entity.

A Subaward does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.

Subaward vs. Vendor/Procurement Agreement

ORA issues all outgoing subawards, while JHU Purchasing handles vendor/procurement agreements. When making the determination as to whether your collaborator is a subrecipient or a vendor, the following* should be considered. *The language below originates from the CFR § 200.330

Characteristics which support the classification of the non-Federal entity as a subrecipient include when the non-Federal entity:

(1) Determines who is eligible to receive what Federal assistance

(2) Has its performance measured in relation to whether objectives of a Federal program were met

(3) Has responsibility for programmatic decision making

(4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award

(5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.

Characteristics indicative of a procurement relationship between the non-Federal entity and a contractor are when the non-Federal entity receiving the Federal funds:

(1) Provides the goods and services within normal business operations

(2) Provides similar goods or services to many different purchasers

(3) Normally operates in a competitive environment

(4) Provides goods or services that are ancillary to the operation of the Federal program

(5) Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar requirements may apply for other reasons.

The Subaward Determination Form, which should be submitted to ORA with your proposal, is found here.

Still not sure if you have a subaward or a vendor? Check the Subaward vs. Vendor Quick Guide

Requesting a New Subaward or Modification

Subaward Requests for new or modification subagreements are submitted and processed through the Subaward Workflow Information Tracking (SWIFT) System. The system can be accessed here by logging in with a JHED ID and password.

When a new grant award or agreement is executed and workflowed to SPSS by ORA, and the award/agreement includes outgoing subawards, a Subawards Checklist will be emailed to department contacts.  The Checklist details all of the documentation required to submit your subaward request, along with tips on how to submit using SWiFT.

To request that ORA draft and issue a subaward, please enter information in the SWIFT system, along with all required attachments, and submit it for processing.

Subaward Process, Responsibilities, and Required Paperwork

SOM ORA Subaward Process

Departmental Responsibilities:

  • Compiling and submitting the required paperwork to ORA via SWIFT
  • Sending a Welcome Packet to new subsites if it is a Federal Award
  • Ensure that Subsite has a DUNS# and SAM Registration if it is a Federal Award
  • Send an invitation to subsite for New Vendor Creation through PaymentWorks

Required paperwork for New Awards:

View the Subaward Forms here.

  1. Detailed subaward Budget
  2. Federally Negotiated Rate Agreement (if applicable)
  3. Scope of Work for Subcontracting PI
  4. Subsite IRB or IACUC Approvals (if applicable)
  5. Subrecipient Questionnaire (if applicable)
  6. Subrecipient Determination Form
  7. Significant Financial Interest Form (for Federal Awards, non-FDP FCOI Clearinghouse subrecipients)
  8. DUNS# and SAM Registration (for Federal Awards)

Required paperwork for Continuation Awards:

  1. Detailed Budget (with Federally Negotiated Rate Agreement, if applicable)
  2. Updated Subsite IRB or IACUC Approvals (if applicable)
  3. Significant Financial Interest Form (for Federal Awards, non-FDP FCOI Clearinghouse subrecipients) to report any changes.
  4. If you have received a REVISED NGA for this award, and the revision affects a subsite, you must provide the requested information.

For additional information or questions on complex subaward requests, please email orasubcontracts@jhmi.edu.

Subrecipient Monitoring and Risk Factors

Subrecipient Monitoring

Federal regulations require the University to monitor our subrecipients to assure compliance with applicable Federal requirements and ensure that performance expectations are being achieved. The University Subrecipient Monitoring Policy is located here.

ORA shall establish a risk classification for each new subrecipient and communicate the rating to Financial Research Compliance (FRC). The subrecipient classification will specify the additional monitoring to be performed by the department that is required for a high risk subrecipient and will include the additional documentation requirements in the agreement.

The process for completing the risk assessment will include:

  • Consulting the Subaward Risk Assessment Spreadsheet;
  • Requiring completion of the “Subrecipient Financial Information Questionnaire” by the potential subawardee, if required;
  • Assigning a risk classification for new subs and communicating to the PI, department and FRC.

Contingent upon the specific subrecipient organization risk classification (high or low) and the nature of the work proposed JHU resources are focused on monitoring the subrecipients who demonstrate the greatest potential for non-compliance.

Risk Factors to Consider

The following subrecipients are considered high risk

  • Foreign subrecipients
  • Domestic subrecipients without a formal compliance audit (A-133)
  • Subrecipients with no prior JHU work history
  • Subrecipients who received less than $1M in federal funding in either of the last two years

The Department and Investigators have important responsibilities in fulfilling the subrecipient monitoring function both prior to and after a subaward is issued, including invoice review and performing desk audits. Please review the University Policy on Subrecipient Monitoring.

 

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