Subrecipients

Pre-award

Virginia Commonwealth University (VCU) is an institutional member of the Federal Demonstration Partnership (FDP), an initiative with 10 federal agencies and over 200 organizations working to identify and demonstrate best practices in research administration. In an effort to reduce the administrative burden associated with the proliferation of what have come to be called “subrecipient commitment forms,” VCU has joined the Federal Demonstration Partnership Expanded Clearinghouse (FDP EC) project, effective July 5, 2017.

As an FDP member and FDP EC participating organization, VCU, when serving as the Pass-through entity (PTE), evaluates a collaborator’s institutional profile information posted here.

All proposed subrecipients must supply a subrecipient mini package to VCU at proposal time to include:

1. Subrecipient commitment form
2. Scope of work
3. Line item budget
4. Budget justification
5. CV/biosketch for key personnel
6. Other documents as applicable, such as a copy of a subrecipient’s federally-negotiated indirect cost rate agreement if they are not participating in the FDP EC

Proposed subrecipients under a federal grant who do not have a federally negotiated IDC rate should be using the de minimis rate. If helpful, provide the following letter to these subrecipients during proposal development: VCU IDC Uniform Guidance letter to subrecipient.

Subrecipient relying on VCU’s Conflict of Interest policy

Proposed subrecipients under a federal grant who do not have an active and enforced conflict of interest policy that is consistent with the provisions of 42 CFR Part 50, Subpart F "Responsibility of Applicants for Promoting Objectivity in Research" or the sponsoring agency’s financial conflict of interest requirement may elect to abide by VCU’s conflicts of interest in research policy. A completed subrecipient interest disclosure form must be returned to airs@vcu.edu prior to proposal submission. Additional steps will be required prior to subaward issuance.

Guidance documentation

• VCU oversight of subrecipients on sponsored projects compliance notice
• FFATA compliance notice

Post-award

Sponsored projects awarded to VCU are generally conducted within the physical boundaries of the university and work is performed by university faculty and staff. Occasionally, however, a portion of the project scope may need to be provided by an external collaborator. The external collaborator is made responsible for a discrete portion of the project, providing the resources necessary to conduct that portion of the work. Costs associated with this work may include personnel costs, supplies, equipment, travel and overhead. Such an arrangement is carried out through the issuance of a Subrecipient Agreement (also called either a subaward or a subcontract).

Associated document/form	How to request a new subaward in RAMS-SPOT How to request a subaward modification in RAMS-SPOT
VCU policy or compliance notice	VCU oversight of subrecipients on sponsored projects compliance notice
Responsible VCU unit(s)	PI / Study staff / Division of Sponsored Programs

Subaward documentation:

Fully executed subaward agreements, amendments and related Direct Pay/Encumbrance (DP/E) forms are accessible in the RAMS-SPOT Subrecipient record. Navigate to the “Documents” tab to view or download subaward documentation.

Subaward payment instructions:

1. Review each invoice for accuracy and allowability.
2. From the RAMS-SPOT Subrecipient record, locate and print a copy of the applicable DP/E form.
3. Complete the DP/E form for the total invoiced amount.
4. Obtain signature(s) on the DP/E form:
   • Fiscal administrator signs as "Requestor"
   • Principal investigator signs as "Approver"
5. Referencing only the DP/E Number in the subject line, attach a single PDF consisting of the signed DP/E form, invoice copy and, for foreign subrecipients, a completed wire transfer request form. Email directly to Accounts Payable at apsubaward@vcu.edu.