Subrecipients and Consultants: Defining and Establishing
When Georgia State University (GSU) receives an award from a sponsoring agency, it may become necessary to establish a subaward agreement with a subrecipient institution. GSU’s Principal Investigator (PI) and administrators will monitor the activities of subrecipients to ensure that they are complying with the programmatic and financial terms of the subaward agreement. Monitoring responsibilities include general compliance and subrecipient audit compliance. Georgia State’s Subrecipient Monitoring Policy applies to all subrecipient institutions with whom Georgia State University executes a subaward agreement, including foreign and for-profit organizations. GSU is responsible for ensuring that all subrecipients of sponsored funds are in compliance with programmatic and financial terms of the subaward agreement.
The Georgia State PI must ensure that, when deemed necessary, all required Conflict of Interest disclosures from consultants have been submitted and training completed prior to the proposal deadline.
The Uniform Guidance, at §200.300 distinguishes contractors (which consultants are) from subrecipients by the existence of the following characteristics:
Contractors. A contract is for the purpose of obtaining goods and services for the non-Federal entity's own use and creates a procurement relationship with the contractor. See §200.22 Contract. Characteristics indicative of a procurement relationship between the non-Federal entity and a contractor are when the contractor:
(1) Provides the goods and services within normal business operations;
(2) Provides similar goods or services to many different purchasers;
(3) Normally operates in a competitive environment;
(4) Provides goods or services that are ancillary to the operation of the Federal program; and
(5) Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar requirements may apply for other reasons.
Unless the sponsoring agency guidelines require any forms or letters related to consultants be included with a proposal, proposals are typically NOT required to include any additional forms related to consultants listed on those proposals.
The Uniform Guidance, at §200.300 defines subrecipients as having the following characteristics:
(1) Determines who is eligible to receive what Federal assistance;
(2) Has its performance measured in relation to whether objectives of a Federal program were met;
(3) Has responsibility for programmatic decision making;
(4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and
(5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.
Each must also provide a description of the scope of work to be provided the project.
Subaward budgets should use the F&A rate set by the subcontractor's institution and a copy of that rate agreement should be provided.
Any subcontracts from other universities must be routed through the subcontracting institution's approval process to obtain the necessary approvals prior to routing the proposal through Georgia State.
A completed Subrecipient Commitment Form for each subrecipient must accompany the proposal. This form, when signed by an authorized official of the subrecipient organization, indicates compliance within all necessary areas and institutional concurrence with the submission.
If the subrecipient institution lacks an active or enforced COI policy, the investigator proposed for the project must fulfill GSU’s CITI training and submit disclosure forms to GSU. See URSA's Conflict of Interest webpage for details.