Subaward Proposal Development Tips
What documentation is needed from a subawardee at the New or Renewal application stage?
SPA always requires the following:
- Statement of Intent (SOI)- provide our version (see forms for individual school's version). If the subcontract institution uses its own form page, review to ensure all requested information is provided.
- Statement of Work (SOW)
- Detailed Budget and Justification (per sponsor requirements)
- Non-Harvard fCOI form, if applicable*
Additional documents commonly collected:
- Biosketches (NIH), or CV, as applicable, for all key personnel
- Facilities & Other Resources (NIH)
- Equipment (NIH)
- Letters of support, if applicable
Other documents that may be required :
Review sponsor guidelines carefully and discuss with your SPA representative as needed
- COMS, IACUC and/or IRB approvals-some sponsors require these at the proposal stage
- Other support for key personnel
- Representations and Certifications (e.g. Requests for proposals a.k.a. RFPs)
- The Federal Acquisition Regulation (52.219-9) requires a Subawarding Plan for Small and Small Disadvantaged Businesses for each contract $650,000 and over. The subawardee may need to submit a federal Subawarding Plan if the subaward exceeds $650,000 (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
- 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?
- 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
- 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.
- 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:
- if a submission should be in modular format.
- if prior approval is needed to submit an application requesting 500k or more in direct costs in any one year.