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6. Sub-recipients
OMB Circular A-110 (Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations) defines a sub-award as an award of financial assistance in the form of money, or property in lieu of money, made under an award by a recipient to an eligible sub-recipient or by a sub-recipient to a lower tier sub-recipient. The term includes financial assistance when provided by any legal agreement, even if the agreement is called a contract, but does not include procurement of goods and services nor does it include any form of assistance which is excluded from the definition of award. A sub-recipient is defined as the legal entity to which a sub-award is made and which is accountable to the recipient for the use of the funds provided. (Foreign organizations may be sub-recipients at the discretion of the sponsor.) While the relationship between UNH and an independent contractor is that of purchaser-vendor, a sub-recipient normally performs a significant portion of the intellectual portion of the project scope of work. Sub-recipients are frequently other academic institutions or industrial partners. When a portion of the project is to be performed by a sub-recipient, the sub-recipient’s detailed budget and justification must be included with the UNH proposal. This information needs to be provided from the proposed sub-recipient’s authorized representative (e.g., Sponsored Research Office) in order to ensure that the costs proposed are supported by and represent an official offer of the sub-recipient’s home organization. Total sub-recipient costs (direct costs and F&A costs) are considered a direct charge to the UNH project. According to UNH’s Federal Rate Agreement, UNH is permitted to charge F&A on total sub-recipient project costs up to the first $25,000 of those costs. (See Budgeting for F&A.) PIs/PDs should contact the OSR GCA for sub-recipient budget specifics when budgeting proposals intended for the National Institutes of Health. |