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More About Outgoing Subawards

A Subaward is an award provided by a pass-through entity [JHU] to a subrecipient for the subrecipient to carry out part of an award received by the pass-through entity.

A Subaward does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.

ORA issues all outgoing subawards, while JHU Purchasing handles vendor/procurement agreements. When making the determination as to whether your collaborator is a subrecipient or a vendor, the following* should be considered. *The language below originates from the CFR § 200.330

Characteristics which support the classification of the non-Federal entity as a subrecipient include when the non-Federal entity:

(1) Determines who is eligible to receive what Federal assistance

(2) Has its performance measured in relation to whether objectives of a Federal program were met

(3) Has responsibility for programmatic decision making

(4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award

(5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.

Characteristics indicative of a procurement relationship between the non-Federal entity and a contractor are when the non-Federal entity receiving the Federal funds:

(1) Provides the goods and services within normal business operations

(2) Provides similar goods or services to many different purchasers

(3) Normally operates in a competitive environment

(4) Provides goods or services that are ancillary to the operation of the Federal program

(5) Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar requirements may apply for other reasons.

The Subaward Determination Form, which should be submitted to ORA with your proposal, is found here.

If you still have questions, please consult our handy Subaward vs. Vendor Quick Guide.

Federal regulations require the University to monitor our subrecipients to assure compliance with applicable Federal requirements and ensure that performance expectations are being achieved. The University Subrecipient Monitoring Policy is located here.

ORA shall establish a risk classification for each new subrecipient and communicate the rating to Financial Research Compliance (FRC). The subrecipient classification will specify the additional monitoring to be performed by the department that is required for a high risk subrecipient and will include the additional documentation requirements in the agreement.

The process for completing the risk assessment will include:

  • Consulting the Subaward Risk Assessment Spreadsheet;
  • Requiring completion of the “Subrecipient Financial Information Questionnaire” by the potential subawardee, if required;
  • Assigning a risk classification for new subs and communicating to the PI, department and FRC.

Contingent upon the specific subrecipient organization risk classification (high or low) and the nature of the work proposed JHU resources are focused on monitoring the subrecipients who demonstrate the greatest potential for non-compliance.

The Department and Investigators have important responsibilities in fulfilling the subrecipient monitoring function both prior to and after a subaward is issued, including invoice review and performing desk audits.

The following subrecipients are considered high risk

  • Foreign subrecipients
  • Domestic subrecipients without a formal compliance audit (A-133)
  • Subrecipients with no prior JHU work history
  • Subrecipients who received less than $1M in federal funding in either of the last two years

For questions about subrecipient compliance, monitoring, and risk factors, please consult the JHU Finance website and review the University Policy on Subrecipient Monitoring.

To request an Outgoing Subaward to be issued, please use the SWiFT system and follow the prompts to submit the required information and/or documentation. Please consult our Request an Outgoing Subaward page for detailed instructions on required documents, department responsibilities, and an overview of the process.

Additional Questions

For other questions, please check our Subaward FAQs section or reach out to a member of the Outgoing Subawards team at [email protected].

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