Subrecipients

Pre-award

Virginia Commonwealth University (VCU) is an institutional member of the Federal Demonstration Partnership (FDP), an initiative with 10 federal agencies and over 150 organizations 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.

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
5. CV/biosketch for key personnel

*Signed AOR Authorization may be (a) a completed sponsor face page; (b) a consortium letter; (c) or a completed version of the Subrecipient project-specific consortium letter (when VCU is PTE)

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

6. a completed and signed VCU entity form for non-FDP expanded clearinghouse subrecipients
7. copy of their negotiated rate agreement, if applicable.

Proposed subrecipients under a federal grant who do not have a federally negotiated F&A rate should be using the 10% de minimis. Provide the following letter to these subrecipients during proposal development. VCU IDC Uniform Guidance Letter to Subrecipient.

Subrecipient relying on VCU’s Conflict of Interest policy

Proposed subrecipients under a Federal grant who do not have an active and enforced conflict of interest policy that is consistent with the provisions of 42 CFR Part 50, Subpart F "Responsibility of Applicants for Promoting Objectivity in Research" may elect to abide by VCU’s conflicts of interest in research policy. A completed Subrecipient Interest Disclosure form must be returned to airs@vcu.edu prior to proposal submission. Additional steps will be required prior to subaward issuance.

Guidance documentation

• VCU Sponsored Programs process when proposal involves a subrecipient and VCU is PTE
• VCU serving as PTE with subrecipients decision tree
• All occasion letter to subrecipient when VCU is PTE
• VCU Oversight of Subrecipients on Sponsored Projects Compliance Notice

Post-award

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	How to request a new subaward in RAMS-SPOT How to request a subaward modification in RAMS-SPOT
VCU policy or compliance notice	VCU Oversight of Subrecipients on Sponsored Projects Compliance Notice
Responsible VCU unit(s)	PI / Study staff / Division of Sponsored Programs

Subaward documentation:

Fully executed subaward agreements, amendments and related Direct Pay/Encumbrance (DP/E) forms are accessible in the RAMS-SPOT Subrecipient record. Navigate to the “Documents” tab to view or download subaward documentation.

Subaward payment instructions:

1. Review each invoice for accuracy and allowability.
2. From the RAMS-SPOT Subrecipient record, locate and print a copy of the applicable DP/E form.
3. Complete the DP/E form for the total invoiced amount.
4. Obtain signature(s) on the DP/E form:
   • Fiscal Administrator signs as "Requestor"
   • Principal Investigator signs as "Approver"
5. Referencing only the DP/E Number in the subject line, attach a single PDF consisting of the signed DP/E form, invoice copy and, for foreign subrecipients, a completed Wire Transfer Request Form. Email directly to Accounts Payable at apsubaward@vcu.edu.