Subcontracts and Consultants

Consultants

Consultants are entities (individuals or companies) receiving a portion of the funds from a grant as an expert advisor or goods/service provider paid by the hour or day for the work they do on the project. Consultants do not maintain rights to IP or authorship for published work from the sponsored project. While a consultant may contribute their expertise on a project, they cannot be named as a Co-PI or Co-Director, nor can they be considered as “key personnel.” Consultant fees may be paid only to experts not employed by Georgia State who provide a unique contribution to the project. In addition, prior approval must be obtained in order for any University System of Georgia and State of Georgia employees to be eligible to receive compensation for consulting services on sponsored projects.

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. See instructions below for details.

What to include for consultants with the proposal

When listing a consultant in the proposal budget, include all their travel expenses and supplies as line items under the “consultant” subheading. Since they are not employed by Georgia State, their travel and supplies cannot be listed under the normal “travel” and “material and supplies.” Consultants fees are generally listed as a daily/weekly rate or a flat fee for services. Because of their classification, consultants are not required to be listed on the Proposal Approval Form.

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. Once a grant is awarded, consultant expenses are treated as any other expense on the award and dealt with as outlined in the Step-by-Step Guide Payment Processing for Independent Contractors / Consultants found on the Office of Financial Accounting, Cashiering & Purchasing Services webpage.

If the consultant is listed as an investigator on the proposal, the PI should complete a Consultant Agreement Form and submit to the Office of Legal Affairs. This form will address the financial conflict of interest requirements for the listed consultant.

Instructions and forms for dealing with consultants on a proposal can be located on the Payments to Contractors / Consultants webpage. Questions about the Conflict of Interest disclosure for a consultant or about the Consultant Agreement Form and process can be addressed to the Office of Legal Affairs (404-413-0500).

Subcontracts

Subcontracts are made to outside entities (subcontractors or subrecipients) that have substantive, programmatic involvement in a specific portion of the proposed project with a separate, itemized budget and specific performance objectives. Subcontractors maintain access to any intellectual property they develop on the project and to publication authorship for their work on the project.

Each subcontractor must have their own itemized budget including salaries, fringe benefits, equipment, travel, supplies, other direct costs, indirect costs and cost sharing. Subaward budgets should use the F&A rate set by the subcontractor’s institution. 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.

Finally, the Georgia State PI must ensure that all required Conflict of Interest disclosures from Georgia State and subrecipient institutions have been submitted and training completed prior to the proposal deadline. See instructions below for details.

What to include for subcontractors with the proposal

Proposals that include a subcontract must be accompanied by a Subrecipient Commitment Form located on the Forms page within this website. Georgia State PI’s or their grants administrator need to complete the top header section and section A on this form. Sections B, C, and D will be completed by an authorized official at the subrecipient institution and the completed form must be submitted to Georgia State’s Office of Sponsored Proposals and Awards (OSPA) prior to the proposal submission deadline.

Item 7 of this form addresses Conflict of Interest. If the authorized official at the subrecipient institution checks the first box within that section (certifying that the institution has an active and enforced COI policy), then the Georgia State PI does not have to list the subrecipient investigators names on the Georgia State Proposal Approval Form. Also, Georgia State does not have to collect COI disclosure forms from the subrecipient investigators or monitor their disclosures and training at the award stage. It is the subrecipient institution’s responsibility to ensure compliance for they own investigators to their own COI policy.

If the authorized official at the subrecipient institution checks the second box within that section (certifying that the institution does not have an active COI policy), and the proposal is going to a PHS agency, then the Georgia State PI will need to include the subrecipient investigators names on their Georgia State Proposal Approval Form, the subrecipient investigators will need to fulfill the COI training and submit disclosure forms to the official email address at Georgia State (see procedures on the Conflicts of Interest webpage), and their disclosures and training will be monitored by Georgia State at the award stage.

If the authorized official at the subrecipient institution checks the second box within that section (certifying that the institution does not have an active COI policy), and the proposal is going to a non-PHS agency, then the Georgia State PI will not need to include the subrecipient investigators names on their Georgia State Proposal Approval Form, the subrecipient investigators will not need to fulfill the COI training or to submit disclosure forms, and at the award stage the authorized official at the subrecipient institution will simply need to certify in the Subcontract Agreement with Georgia State that either a) no conflict of interest exists or b) any research conflict of interest that does exist has been disclosed to Georgia State.

The Subrecipent Commitment Form should be accompanied by a description of the scope of work that the subcontractor will conduct towards the project, an itemized budget specifying any cost share to be provided by the subrecipient, and include a copy of their institution’s F&A rate agreement. NOTE: For further clarification on subcontracts in a proposal, contact the Office of Sponsored Programs (413-3550).