16.3 Issuance of a Subaward


Questions about this policy can be answered by:

Register, Laura

Subrecipient Monitoring Officer, OSR

Office of Sponsored Research Pre Award

(303) 838-2163

1. Authorization for Subrecipient to Begin Work

A subaward authorizing the subrecipient to begin work can only be issued after the prime agreement from Stanford’s sponsor has been accepted on behalf of the institution.  A subaward will not be issued, nor payments to a Subrecipient authorized, prior to Stanford's receipt and acceptance of a funding commitment from the prime sponsor. A Stanford PI or designee may not authorize a subrecipient to begin working without a fully executed subaward agreement in place. Proposed subrecipients who commence work without a fully signed subaward agreement from OSR do so at their own risk and have no assurance of payment from Stanford. In the event a subaward is subsequently issued to a subrecipient, a subrecipient may claim costs properly incurred under its own risk, provided that the costs are otherwise allowable. In such cases, the Subrecipient must furnish evidence to Stanford that all required compliance approvals were in place at the time the costs were incurred.

After an award has been accepted and a financial account established by Stanford University, the PI or his/her authorized administrator may submit a request to issue a subaward. This request documents the amount authorized by the PI for the subaward and delineates the desired period of performance. OSR is not authorized to issue a subaward until an approved request is on file.

The following items must be present in order for OSR to begin drafting the subaward agreement.

  • Subrecipient Statement of Work

  • Subrecipient Budget that aligns with the amount of the requisition

  • Subrecipient’s OSR Form 33

  • OSR Form 45 (only if the prime is a federal contract)

As part of its subaward issuance process, OSR’s Contract & Grant Officers and Subrecipient Monitoring Officer will collect additional compliance documentation and issue subawards in compliance with sponsor terms and applicable regulations, including the OMB Uniform Administrative Guidance, Sections 200.330-332.

Modifications to existing subawards are issued by OSR in response to requisitions submitted by a PI or his/her designee.  PIs may not reduce obligated funding or prematurely terminate an approved subaward unless they submit a corresponding requisition to OSR to request a formal change in their subaward.  In such cases, Stanford is required to honor the terms of the subaward, which typically require an advance notice period.

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2. Subawards Periods of Performance and Duration

The period of performance of a subaward (including any requested extensions) may not be outside of Stanford's period of performance allowed under the prime award. Subawards may, however, be issued for shorter periods of time than Stanford's full period of performance. A new subaward will be issued whenever Stanford's sponsored project receives funding under a new competitive segment.

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3. Subaward Funding Mechanisms

Stanford issues subawards on a cost-reimbursement basis. Rare exceptions may be made when it can be demonstrated that a fixed-price agreement is in the best interest of the university.  For subawards issued under federal awards, per OMB Uniform Guidance, Section 200.332, prior written approval from the prime sponsor will be required on fixed-price subawards up to the Simplified Acquisition Threshold.

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4. Initiating aSubward After the Proposal is Submitted

A PI may decide to engage the services of a Subrecipient after the proposal has been submitted to the prime sponsor. In this case, the PI must submit the required elements for a subaward to OSR as described in this policy. In many cases, sponsor prior approval will be required. PIs are responsible for initiating such requests for Sponsor approval, and for obtaining the countersignature of their authorized institutional official as required. Subawards may not be issued until all necessary sponsor approvals are obtained.

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