Subawards for Foreign Grants
Subawards and other collaborations can play an important role in an international research project. This part describes the role of the grantee and subaward organization.
It shows how to design an effective subaward agreement, manage a subaward and make changes to an existing subaward.
Working With Collaborators at Other Sites
Subaward agreements are between you—the grantee—and the subawardee. They do not involve NIAID.
At any point during your award, you may need to involve collaborators. One way to do that is to create a subaward (also called a consortium agreement) for researchers, institutions, or organizations that you want to play an active role in your research project.
Subawards allow another organization to perform some activities for your grant under your supervision. They enable collaborations between a grantee and another organization—the subawardee.
This agreement is between you—the grantee—and the subawardee. It does not involve NIAID. You are responsible for the actions of the subawardee.
Think about this arrangement as a bicycle wheel formed from a hub with spokes. NIAID—the pedal—gives money and authority directly to you through your institution—the wheel's center.
You work directly with the subawardees—the spokes—and are accountable for their performance, expenditures, and activities. The research forms the rim, which completes the wheel and propels everybody forward.
Roles and Responsibilities When Using Subawards
As the grantee, you—not the subawardee—are accountable to NIAID.
In managing their subawards, grantees are fully responsible for the following:
- All actions of the subaward related to the award.
- All contact with NIAID. If we need information from your subawardees, we will contact you.
As the grantee, you (not the subawardee) are accountable to NIAID for the performance of the research project, spending of grant funds by all parties, reporting requirements, negotiating animals in research and human subjects assurances, and all other obligations for the grant.
- You must play a substantive role in the research; you cannot just pass along funds to another institution.
- If there's a problem with a subawardee, we expect you to take care of it.
Do You Need a Subaward or a Consultant?
Talk to your business office or program officer when deciding whether to use a subaward or consultant.
Subawardees should make major contributions to the project. Use a subaward when you need another institution for the design, conduct, or outcome of your project.
For help filling in smaller gaps hire a consultant instead. Consultants usually provide advice or services—for example, supplying software, making technical comments, or setting up equipment—and sometimes participate significantly in the research. They work for a fee; for information on paying consultants, see Consultants under What Are Allowable Costs? in Receiving and Spending Money.
Ask your institution's business office or speak to your program officer when deciding whether to use a subaward or consultant.
If you decide on a consultant, you need a letter describing the consultant's willingness to participate in your project and his or her role.
- Send your consultants a sample letter they can return to you with their signature. That way, the letter will contain all the information you need, and they may return it to you faster.
- The letters go in the grant application. Attach as Letters of Support to the PHS 398 Research Plan form.
If you decide on a subaward, continue reading.
You need to have an agreement in place before you can pay a subawardee with NIAID funds.
For each subaward, your institution outlines the details of the arrangement in a written formal agreement. You need to have an agreement in place before you can pay a subawardee with NIAID funds.
To create a subaward, prepare a written agreement with each subaward partner to describe how everyone will meet the scientific, administrative, financial, and reporting requirements of the grant. Your goal should be a smooth, orderly collaboration.
Address the following in your agreement:
- Scientific work scope. See Importance of Scope of Research in Actions You Can Take as the Project Leader.
- Terms and conditions of award
- Administrative requirements
- Reporting requirements
Include the following items:
- Name of principal investigator and others responsible for the research activities at each site; list their roles and responsibilities
- Roles for managing the research
- Conflict of interest requirements of the collaborating organization
- Rules for owning and handling data
- List of NIH requirements and compliance documents
- Plans for the following:
- Managing the research.
- Reimbursing subaward costs, considering foreign exchange rates, payment schedules, and accounting methods. NIAID does not cover costs associated with currency fluctuations after the initial award. Make sure you are aware of Cost Principles in Compliance for Foreign Grants.
- Handling travel reimbursement, salaries, and fringe benefits.
- Sharing inventions and patents.
See examples at the Federal Demonstration Partnership's Subaward Agreement Forms.
Policy Requirements for Subawards
Foreign subcontracts under NIH grants must adhere to the public policy requirements in the NIH Grants Policy Statement. In addition, they must have assurances filed with NIH that cover the activities that relate to the project. These requirements must be part of the formal written subcontract agreement with the grantee and include
- Human subjects
- Research misconduct
- Research involving vertebrate animals
- Inclusiveness in research design
- Non-delinquency for any federal debts
- Drug-free workplace
- Financial conflict of interest
- Debarment and suspension—applies to all except foreign government or public international organizations
Budget Requirements for Subawards
Keep a detailed budget for all grant years of your subawards.
Each subaward should have its own budget. Your institution distributes funds directly to subawardees according to the terms and conditions of award.
As you manage your grant, make sure you maintain a detailed budget for all grant years of your subawards.
Keep the following points in mind:
- The grantee determines each subaward's budget.
- Subawards have the same allowable and unallowable costs as the grantee.
- For facilities and administrative costs
- Foreign subcontract budgets should include up to 8 percent of the modified total direct costs of the budget, excluding equipment, tuition and related fees, and subawards over $25,000 to pay for compliance with NIH policies and regulations.
- Domestic subcontract budgets should include the negotiated F&A rates.
- For more information, see Facilities and Administrative Costs in Receiving and Spending Money.
- Your subawardees can't enter into subcontracts with any third parties, but they can make purchases and hire consultants who don't affect the scientific direction of your project.
- Subawardees don't have any budget authority that NIH has not provided in your Notice of Award.
As you work with your subaward sites, be sure your Federal Financial Reports include the actual costs, in U.S. dollars, for each subaward.
See What Are Allowable Costs? and Unallowable Costs in Receiving and Spending Money.
You will need to arrange for an annual audit if your institution spends $750,000 or more a year of HHS award money, whether it is the grantee or on a subaward. See Meeting Your Audit Requirements in Other Reporting Requirements.
Changing a Subaward
Know which subaward changes you can make on your own and which require our approval.
Make sure everyone involved knows that an agreement can change and how to change it if needed.
Changes to a subaward follow the same rules as changes to your grant. Review Actions You Can Take as the Project Leader to see what changes you can make on your own and what changes require our approval.
If your request needs our approval, ask your business office to email the following information to your grants management specialist at least 30 days before the requested change:
- Grant number
- Principal investigator name, title, organization, and contact information
- Reason for the change
- Whether it results in a change in scope or Specific Aims
We will review your request and respond within 30 days. To help us get you the quickest response, send in this information when we request it:
- An updated All Personnel Report
- A detailed budget for a new site, or an updated detailed budget if removing a site or making other changes
- Documentation of a Federalwide Assurance for human subjects and Animal Welfare Assurance for animals in research and applicable certifications (IRB or IEC)
- For new key personnel, a biosketch, other support information, and the required documentation of education in the protection of human research participants, if applicable
When preparing a progress report, follow the instructions at Annual Progress Report.
Proceed to Compliance for Foreign Grants (next page) or return to Grants Management for Foreign Awards.