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Virginia Commonwealth University (VCU) is an institutional member of the Federal Demonstration Partnership (FDP), an initiative with 10 federal agencies and over 150 institutions working to identify and demonstrate best practices in research administration. In an effort to reduce the administrative burden associated with the proliferation of what have come to be called “subrecipient commitment forms”, VCU has joined the Federal Demonstration Partnership Expanded Clearinghouse (FDP EC) project, effective July 5, 2017.

As a participant in the FDP EC project, VCU, when serving as the Pass-through entity (PTE), now evaluates a collaborator’s institutional profile information posted here.

Desktop reference of current EC participants

All proposed subrecipients must supply a subrecipient mini package to VCU at proposal time to include:

  1. Signed AOR Authorization*
  2. Scope of work
  3. Line item budget
  4. Budget justification, and
  5. CV/biosketch for key personnel

*Signed AOR Authorization may be an AOR-signed sponsor face page, or AOR-signed Subrecipient Project-Specific Consortium Letter (when VCU is PTE), or Subrecipient’s own AOR-signed Consortium letter.

Proposed subrecipients who are not participating in the FDP Expanded Clearinghouse project, must also provide the following:

  1. a completed and signed VCU Entity Form for non-FDP Expanded Clearinghouse Subrecipients, and
  2. copy of their negotiated rate agreement, if applicable.

Guidance Documentation

Subrecipient Relying on VCU’s Conflict of Interest policy

If your subrecipient does not have an active and enforced conflict of interest policy that is consistent with the provision of 42 CFR Part 50, Subpart F “Responsibility of Applicants for Promoting Objectivity in Research” and intends to abide by VCU’s Conflicts of Interest in Research policy, then additional steps may be needed.

Sponsored projects awarded to VCU are generally conducted within the physical boundaries of the University and work is performed by University faculty and staff. Occasionally, however, a portion of the project scope may need to be provided by an external collaborator. The external collaborator is made responsible for a discrete portion of the project, providing the resources necessary to conduct that portion of the work. Costs associated with this work may include personnel costs, supplies, equipment, travel, and overhead. Such an arrangement is carried out through the issuance of a Subrecipient Agreement (also called either a subaward or a subcontract).

Associated Document/Form
VCU Policy or Compliance Notice Establishment of Sponsored Project Subcontracts and Subawards
Responsible VCU Unit(s) PI / Study Staff / OSP