Subaward Changes

Increases subrecipient monitoring responsibilities, limits each fixed price subaward to $150,000, and provides a 10% de minimis F&A rate if a subrecipient does not have a negotiated rate.

Last Updated: 3/15/2015


Stanford Summary

  1. The Uniform Guidance requires increased scrutiny of the subrecipient F&A at the time of proposal, and increases emphasis on risk analysis prior to issuing a subaward.
  2. With prior approval, fixed price subawards of up to $150,000 are permissible under the Uniform Guidance
  3. Additionally, the Guidance clarifies that if a subrecipient does not already possess a negotiated Indirect Cost Rate, it may apply a de minimis 10% rate on MTDC.. 

Application at Stanford

The Uniform Guidance is effective for federally sponsored agreements and new funding increments awarded on or after December 26, 2014. Federal awards received before December 26, 2014 must continue to follow the requirements in OMB A-21 and Stanford’s policy on Subawards (RPH Chapter 16).

Through the OSR Form 33, Stanford collects detailed information regarding a subrecipient’s F&A rate at the time of proposal.  Stanford’s policy requires that this Form be collected at the time of proposal.  Institutional Officials will review subrecipient’s F&A rates to ensure compliance with the new requirements for entities who do not have a federally negotiated rate.

As part of its subaward issuance process, OSR has been conducting a detailed risk analysis prior to issuing a subaward.  OSR performs both an annual entity-level analysis, and project-specific analysis.  Entity level analysis includes elements such as review of  prior audit results or financial  documents, entity-level controls, established  systems, infrastructure, maturity and experience.  Project level analysis includes elements such as review of the scope of work, deliverables, amount of the subaward and the percentage of the prime award.

Stanford issues primarily cost-reimbursement subawards.  However, there are times when a risk profile or nature of the work dictate that a fixed-price approach would better protect Stanford.  In such instances, Stanford will now be required to secure prior sponsor approval prior to issuing a fixed-price subaward.  In the event that the subrecipient’s budget exceeds the simplified acquisition threshold, Stanford will work with the PI to determine alternative mitigation measures in order to proceed with the subaward.

Affected Stanford Policies

RPH Chapter 16 Subawards