16.3 Issuance of a Subaward

Contact

Questions about this policy can be answered by:

Register, Laura

Subrecipient Monitoring Officer, OSR

Office of Sponsored Research Pre Award

(650) 422-4546

1. Pre-Award Spending on Subawards

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.

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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 for a competitive segment 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.

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4. Sole Source Justification Form

A separate Sole Source Justification Form (See OSR Form 45 found below in "Related Items") is required for all subawards under contracts (whether or not included in Stanford's proposal to the sponsor). This form must be completed by the PI prior to a subaward being issued.

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5. Initiating an Unanticipated Subward 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 Section 4 above, including a Sole Source Justification. In many cases, sponsor prior approval will be required (for rebudgeting, to add a new Subaward, and/or to obtain approval for a change in scope or methodology). PIs are responsible for initiating such requests for Sponsor approval, and for obtaining the countersignature of their authorized institutional official. Subawards may not be issued until all necessary sponsor approvals are obtained.

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6. Requesting Issuance of a New Subaward

After an award has been accepted by Stanford University and an account (PTA) established in Oracle, the PI or his/her authorized administrator will submit a requisition through Oracle identifying the proposed Subrecipient. 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 requisition is on file. The Procurement Department will forward the requisition to OSR.

If the Subrecipient's SOW or Budget has changed, updated information should be provided to OSR; otherwise, OSR will use the information contained in the proposal/award file. In addition, the following items must be on file before a subaward is issued:

  1. Copies of the Subrecipient's F&A and Fringe Benefit rate agreements
  2. Copies of the Subrecipient's human subjects approval and approval to use animals, if applicable
  3. A copy of the Subrecipient's most recent A-133 audit or link to its record on the Federal Audit Clearinghouse, or completion of the Audit Certification and Financial Status Questionnaire (OSR Form 47, found below in "Related Items"), if not provided at the time of proposal
  4. Any applicable requested information (Subrecipient Commitment form, updated Certificate of Cost or Pricing Data, Small/Small Disadvantaged Business Plan, audit information, etc.)
  5. Sole Source Justification, if required
  6. Any special requirements the PI wishes to impose (prior approval requirements, report formats, or due dates, etc.)

OSR will consult with the PI and/or departmental administrators as needed to clarify requirements or to obtain additional information.

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7. Requesting Modifications to Existing Subawards

Modifications to a subaward are issued by OSR in response to requisitions submitted through Oracle by a PI or his/her designee. This includes modifications to the Statement of Work, incremental funding, rebudgeting, extending or reducing the time for performance, and other changes in the terms of a subaward. In rare instances, OSR may initiate action on a subaward without a corresponding requisition; typically these changes involve urgent action on a subaward that is initiated by the University. 


PIs may not reduce obligated funding or prematurely terminate an approved subaward unless they submit a corresponding requisition through Oracle 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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