Subrecipient process changes
January 22, 2016
NAU’s subrecipient commitment form has been revised to include only the minimal required information for proposal submittal. It has been reduced from six pages to two. The PI is requested to complete only Section A of the form. The remaining sections are to be completed by the proposed subrecipient. The form requests information that should be readily available to the subrecipient. In case there are questions, the subrecipient is requested to contact the Office of Sponsored Projects (OSP.) The subrecipient commitment form instructions have also been revised accordingly. They are both available at: https://in.nau.edu/osp/forms-worksheets-tools/
Once the potential subrecipient is identified and it is determined that a subagreement is the appropriate mechanism, the PI will obtain a completed subrecipient commitment form including the Statement of Work (SOW), Budget and Budget Justification from the subrecipient.
Per the new Uniform Guidance regulations, which became effective December 26, 2014, NAU must make case-by-case determinations (third party determinations) whether each subagreement it makes for disbursement of federal program funds casts the party receiving the funds in the role of a subrecipient or a vendor. Prior to inclusion in the NAU proposal,OSP will review the subrecipient’s SOW and complete the Third Party Determination Form. OSP will insure that any sponsor specific solicitation requirements are also obtained from the subrecipient prior to proposal submittal.
Once the award to NAU is imminent, OSP will obtain any additional information from the subrecipient that is required for subagreement award. This may include but not be limited to a completed audit certification form. OSP will coordinate with the PI to obtain as necessary, a detailed SOW, required deliverables, specific reporting requirements, period of performance terms and past performance history. If the prime award is a federal contract, OSP will obtain information from the PI to allow for completion of the necessary sole source justification and cost/price analysis.
OSP will use subrecipient information to develop the subagreement and perform the required risk assessment.