Subaward Resources

Subaward Proposal Development Tips

Collecting Information:

What documentation is needed from a subawardee at the New or Renewal application stage?

  • Statement of Intent (NIH) or Letter of Commitment with authorized institutional official signature (most other sponsors) that, preferably, includes a debarment certification.
  • Detailed Budget (with justification and authorized institutional signature).
  • CVs of Key Personnel.
  • Current/Pending Support of Key Personnel (for NIH, Just-in Time).
  • Representations and Certifications, as applicable (e.g. Requests for proposals a.k.a. RFPs).
  • Subawardee’s federal identification number (EIN).
  • Negotiated Indirect Cost Rate Agreement – to verify subawardee’s rate.
  • The Federal Acquisition Regulation (52.219-9) requires a Subawarding Plan for Small and Small Disadvantaged Businesses for each contract $500,000 and over. The subawardee may need to submit a federal Subawarding Plan if the subaward exceeds $500,000 (total costs over the entire project period) and if HSPH award is a federal contract or a subaward under a federal contract.

What documentation is needed from a subawardee for non-competing NIH Progress Reports included under the Streamlined Noncompeting Award Process (SNAP)?

  • Detailed Budget (with justification and authorized institutional signature).
  • Information on change in effort or other support of key personnel as applicable.
  • Evidence of continuing IRB or IACUC protocol approvals as applicable.

Evaluating Subaward Proposal Materials

PI’s role:

  • Has the subawardee’s PI described the proposed work accurately, adequately and appropriately?
  • Do the budget line items seem reasonable, allowable, and allocable given the Subawardee’s proposed Scope of Work?

Administrator’s role:

  • Analyze proposed costs. Are they allowable, allocable and reasonable?
  • Verify subawardee’s indirect cost rate.
  • Note: NIH allows an 8% rate for most foreign institutions to be applied to their total direct costs.
  • For subawardees without a federally negotiated rate, consult SPA.
  • Work with collaborating institution administration to address any questions or concerns.

Factoring Subaward costs into Harvard’s F & A Base

Federal Funds:

  • For Federal Proposals, first 25K of the subawardee’s total costs (the “cap”), may be included in the School’s MTDC.  MTDC is the base on which the School’s F&A rate is applied.
  • If the subaward in year 1 is less than 25K, then the School’s F&A for the 2nd year must include the balance.
  • Please note the 25K cap routinely applies to Federal awards. A few non-federal sponsors use the same cap.

Non-Federal Funds:

  • The base for applying F&A varies among non-federal sponsors.
  • A ceiling or limitation similar to the 25K federal cap may apply. Check sponsor guidelines.
  • If there is no ceiling specified in the sponsor’s guidelines, F&A must be applied to the full subaward amount.

Federal and Non-Federal Funds:

  • The subawardee’s F&A is the School’s direct cost. Note: for new and renewal applications to NIH, subaward F&A should not be factored into direct costs for purposes of determining:
    1. if a submission should be in modular format.
    2. if prior approval is needed to submit an application requesting 500k or more in direct costs in any one year.