Subaward Policy

EFFECTIVE DATE: May 1, 2009 |LAST UPDATED: April 24, 2012 | Policy Section: sponsored-research

Responsible Executive

Jeffrey Friedland

Responsible Office

Office of Research and Project Administration


Jeffrey Friedland, or (609) 258-3090

I. Policy StatementBACK TO TOP

As the prime recipient of a sponsored program or program award, the University is accountable to the federal or non-federal sponsor for the subrecipient’s actions with respect to compliance with Office of Management and Budget Cost Principles and administrative compliance matters. Therefore, the University must monitor the subrecipients' activities in order to provide reasonable assurance that subrecipients administer subaward funding in compliance with sponsor requirements.

II. Who is Affected by this PolicyBACK TO TOP

This policy applies to all sponsored projects and programs. It should be understood by Principal Investigators (PIs), Grant Managers, Department Managers, Department Chairs, Sponsored Research Accounting (SRA), and the Office of Research and Project Administration (ORPA).

III. Definitions

Pass-through entity - A non-sponsor entity that provides a prime sponsored award to a subrecipient to carry out a portion of the prime sponsored award’s program

Subaward - A formal written agreement made between the University and a Subrecipient in order for the Subrecipient to perform a portion of the University’s scope of work under a sponsored project or program that incorporates the sponsored award terms and conditions

Subrecipient – In accordance with Office of Management and Budget Circular A-133, a Subrecipient is a non-prime-sponsor entity that expends awards received from the University as a pass-through entity in order to carry out a portion of the University’s programmatic effort under a sponsored project or program. The Subrecipient may be a domestic or foreign educational institution, for-profit corporation, or non-profit organization. An individual cannot serve as a Subrecipient.

Vendor - A dealer, distributor, merchant, or other seller providing goods or services that are required for the conduct of a federal program.


The University follows the requirements found in Office of Management and Budget Circular A-133 (Section B.210) to distinguish subawards from other procurement actions. There may be unusual circumstances or exceptions to the listed characteristics. In making the determination of whether a subrecipient or vendor relationship exists, the substance of the relationship is most important.

The University will issue a subaward when the organization:

  • Determines who is eligible to receive what sponsored award assistance;
  • Has its performance measured against whether the objectives of the sponsored project or program are met;
  • Has responsibility for programmatic decision-making;
  • Has responsibility for adherence to applicable sponsored award compliance requirements; and
  • Uses sponsored award funds to carry out a program (Statement of Work) of the University as compared to providing goods or services to the University.

The University will use other procurement actions when the vendor:

  • Provides the goods and services within its normal business operations;
  • Provides similar goods or services to many different purchasers;
  • Operates in a competitive environment;
  • Provides goods or services that are ancillary to the operation of the University’s sponsored project or program; and
  • Is not subject to compliance requirements of the sponsored award.

The appropriate classification of a transaction as a subaward or other procurement action at the time it is proposed and funded is essential for ensuring proper accounting for costs and compliance requirements. Misclassification may result in delays in processing and inaccurate calculation of sponsored award costs, which may result in insufficient award funding available to the University’s PI.

Subawards issued by the University must be initiated, monitored, modified, and closed by ORPA when the subaward is issued under an externally-funded sponsored project or program. The University has the responsibility throughout the lifetime of the subaward agreement to monitor the activities of subrecipients in accordance with the terms and conditions of the prime sponsored award. The PI is responsible for the management and administration of the subaward in accordance with the sponsored award and University policy.

Vendor relationships may be initiated and monitored directly by the Department and the Purchasing Department.

V. Procedures BACK TO TOP


VII. Contact Roles and Responsibilities BACK TO TOP

Department Administrator Determines vendor or subrecipient relationship
Principal Investigator Determines the need for third party participation in sponsored project or program
ORPA Determines vendor or subrecipient relationship





Updated hyperlinks


Reorganized sections to convert to University-approved policy template without alteration to policy content


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