If you don't need an introduction to subawards, please turn to our pages on Subrecipient Determination and Subaward Issuance or Subrecipient Monitoring. If you are new to subawards, below we spell out the basics.

A Short Introduction to Subawards

Subawards are usually federal in origin and are thus governed by the federal regulation entitled Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (2 CRF 200), also known as Uniform Guidance (UG). 

In the parlance of research administration, the term "subaward" has two meanings. Both derive from the  relationship of two institutions, one conducting work on behalf of the other.

1. The term means, first, an award provided to an institution (S) through a contractual arrangement with another institution (P), which has been granted pass-through funding, usually by a federal agency. The "pass-through entity," also referred to as the "prime awardee," proposes the project and is awarded the funding directly by the sponsor. The subawardee, identified by UG as the "subrecipient," is typically included in the original proposal to conduct some of the work specified in the proposal.

2. The term "subaward," via metonymy, is also an abbreviation for the subaward agreement that is legally contracted between the "prime" and the "sub." In such agreements, the prime has more responsibilities, mirroring the greater responsibilities of the prime to the sponsor.

*Please note: UG cost principles depend upon the type of awardee institution.  As a hospital, BMC is subject to its Appendix IX, which refers the reader to 45 CRF 75, Appendix IX.

Outgoing or Incoming?

Subawards are categorized as outgoing or incoming, capturing the differing perspectives of the prime and sub.

Outgoing subawards are those that the prime awardee issues to the subrecipient.  When BMC is the prime awardee of pass-through funding, BMC issues an outgoing subaward to its collaborating institution(s). Incoming subawards are those that the sub accepts. When BMC is the subawardee (subrecipient) of another institution's primary award, the subaward is incoming.

Both prime and sub awardees have crucial responsibilities, but the prime awardee has considerably more.

Outgoing Subawards

When BMC is the prime awardee, subrecipients should be included, justified, and budgeted in the proposal. After receiving the prime award, BMC will issue a subaward to establish the framework when a substantive portion of the programmatic work in a project is conducted at another organization. BMC:

  • Creates a formal, collaborative sponsored activity relationship with the other organization,
  • Identifies roles, responsibilities, expectations, and
  • Flows down terms and conditions from BMC’s prime award to the subrecipient

See BMC's policy on Subaward Agreements.

Subrecipient Determination

One of the striking features of UG rules related to subawards is its requirement that the prime awardee (pass-through entity) conduct a case by-case determination of whether or not the collaborator is a subrecipient rather than a contractor. The requirement suggests that federal agencies found that some institutions were mis-assigning responsibilities, creating a greater burden than needed.  

Contractors are vendors or consultants whose contributions do not rise to the level of subrecipient.  At BMC, we distinguish between vendors of goods and services  and consultants. The former is managed by Supply Chain Operations, the latter, by Human Resources.

Go to our Subrecipient Determination page for the determination tool and other relevant information

Subrecipient Risk Assessment and Monitoring

Among the federally required responsibilities of the prime awardee is subrecipient risk assessment and monitoring.  Sponsored Programs Administration (SPA) personnel conduct the assessment and update it as needed. The PI is responsible for subrecipient monitoring and may be aided by a department administrator (DA).

PIs and DAs engaged in projects including BMC subrecipients should consult our subrecipient monitoring page for more details and BMC's policy on Subrecipient Risk Assessment and Monitoring.

The subrecipient risk assessment is conducted by Sponsored Programs Administration (SPA) personnel on behalf of the PI and their department.  Subrecipient monitoring is the responsibility of the PI.

Incoming Subawards

Incoming subawards at BMC are those that specify BMC as the subrecipient.  The responsibilities are not inconsiderable but they are lesser than those when BMC is the prime awardee/pass-through entity.  Please review the "When BMC is the Subawardee" section of our Introduction to Proposals for more information.

Principal Investigators and Subinvestigators

Please note that, by federal regulation, the awardees, prime or sub, are the institutions, not the individuals conducting the work.  There are multiple reasons for this, not least the weight of compliance assurance.  For departments and investigators, the meaningful roles are principal investigator (PI) of the overall award and sub-investigator (Sub-I) of the subaward. At the subawardee institution (= subrecipient), the sub-I is often named the PI, but that indicates that the investigator is principal only for the work of the subrecipient.