Subaward Classification

Subaward Classification

 

The grid below is intended to assist in classifying collaborations with external organizations for proposals and awards.   The classifications are based upon regulatory requirements as described in the Uniform Guidance CFR 200.330.
OSP recognizes that there are situations that are gray and we encourage you to work with OSP staff to make determinations.   

 

 

 

Type of Classification Criteria and Examples
Subrecipient/Subawards

For the purpose of carrying out a portion of an award, one entity is designated as the primary performance site/grantee.  If another entity carries out a substantive portion of the work in their own space, formal subcontracting arrangements should be established to protect both institutions and ensure agreement with sponsor's assurances and certifications and all institutional, federal and sponsors' regulations.

Criteria from Uniform Guidance (CFR 200.330)

  • The entity receiving the Subaward: Determines who is eligible to receive what assistance. Has its performance measured in relation to whether objectives of a Sponsored Program are met.
  • Has responsibility for programmatic decision-making. Is responsible for adherence to applicable Sponsored Program requirements specified in the Sponsor's award.
  • Uses the Sponsored Program funds to carry out a program for a public purpose specified in authorizing statute or specified in the Sponsored Program's terms and conditions, as opposed to providing goods and services for the benefit of the Pass-through Entity.

Additional Indicators that a subrecipient relationship is appropriate:

  • A principal investigator has been identified at the subrecipient site and functions as a "Co Investigator" or key personnel. Participates in a creative way in designing and/or conducting the research.
  • Publications may be created or co-authored at the subrecipient site.
  • Substantive, programmatic work or an important or significant portion of the research program or project is carried out at the subrecipient site. There is the expectation that the subrecipient entity will retain ownership rights in potentially patentable or copyrightable technology or products that it produces in the course of fulfilling its scope of work.
  • The subrecipient entity provides cost sharing or matching funds which are not reimbursed by DC or the prime sponsor.
  • The entity regards itself, and/or is regarded by Dartmouth College "DC", as "engaged in research" involving human subjects under the Common Rule and therefore requires approval for its interactions with human subjects.

Purchased Service/Consulting Services/Procurement Contract

 

Criteria from the Uniform Guidance

The entity receiving the procurement contract or providing the purchased service:

  • Goods and services provided are within normal business operations. Provides similar goods and services to many different purchasers. Normally operates in a competitive environment.
  • Provides goods or services that are ancillary to the operation of the Sponsored Program.
  • Is not subject to compliance requirements of the Sponsored Program as a result of the agreement, though similar requirements may apply for other reasons.

Additional Indicators that a contractor/vendor relationship is appropriate:

  • Use of shared service/resource cores would indicate a purchased service or procurement relationship. Non-faculty scientific resources, such as analyst or technical laboratory services (assays, lab testing, etc).
  • Contractor/vendor has not significantly participated in the design of the research itself, but is implementing the research plan of the principle investigator/prime awardee.
  • Contractor/vendor is not directly responsible to the sponsor for the research or research results. Contractor/vendor does not expect to have its employees or executives credited as co-authors on papers that emerge from the research.
  • The expectation is that the work will not result in patentable or copyrightable technology or products that would be owned by the contractor/vendor. The contractor/vendor markets its services to a range of customers, including those in non-academic fields.
  • Little or no independent decision-making is involved in the design and conduct of the research work being completed by the contractor/vendor .
  • The agreement only specifies the type of goods/services provided and the associated costs. In the case of an individual vendor of consulting services, the person has no employment relationship with DC
 Salary Billing Arrangement

Description:

Billing agreements are for the reimbursement of salary and fringe to the investigator's/ researcher's paymaster/ employer institution. IDC is not recoverable as overhead costs are not incurred. Prime Awardee is responsible for collection of Conflict of Interest assurances for individuals paid under a billing agreement who are responsible for the design, conduct or reporting of the research.

Criteria:

  • Faculty/staff/trainee is employed by, on the payroll of, and receives their salary from the non-grantee institution.
  • Role of the individual on the sponsored project does not meet criteria for subaward as per Uniform Guidance, as outlined above.
  • Research or performance of an ongoing role on a project will be conducted in the space of the institution where the grant is awarded.
  • Reimbursement from the grantee institution for direct costs of salary and fringe benefits is requested by the non-grantee institution incurring the actual payroll cost. If reimbursement of non-personnel expenses are required, a formal subcontract arrangement is necessary.