Subawards

What is a subaward?

If you are collaborating with researchers at another institution on a proposal and IU is the lead institution, a subaward may be required.

A subaward (also referred to as a subgrant or subcontract) is financial support from a prime awardee (e.g., Indiana University) to a qualified organization for performance of a substantive portion of the programmatic effort under the prime award. Subaward agreements are negotiated between the two institutions after the prime award is received.

Proposal requirements for subawards

If your proposal includes a subaward, the Office for Research Administration will need the following from the subawardee institution:

  • Budget
  • Budget justification or budget narrative
  • Statement of work to be performed by subawardee
  • Signed Subrecipient Commitment Form
  • A copy of the Subawardee's F&A rate agreement or hyperlink to their rate agreement (if applicable)
  • NIH applications with foreign subrecipients must include a Letter of Support from the subrecipient PI for with a statement acknowledging their willingness to abide by NIH NOT-OD-23-182 as part of the NIH application. Specifically, we recommend international subrecipients use the following language in their letter of support when they will be included in NIH proposals:
 
By signing this subrecipient letter of support, [subrecipient PI name] agrees to provide access to copies of all lab notebooks, all data, and all documentation that support the research outcomes as described in the progress report, to [primary recipient] with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report. Such access may be entirely electronic.
Read the IU policy on Subrecipient Monitoring
Learn more about subrecipient monitoring

NIH Foreign Subaward & Foreign Component FAQs

NIH has not yet provided explicit guidance for proposal submissions; therefore, it is at the discretion of the PI/School to move forward with foreign subrecipients.

At this time, subrecipients already approved by NIH will continue to have their foreign subawards/amendments drafted for awards already in place.

NIH has not yet provided specific guidance on upcoming or pending proposals; however, they have indicated that there is a temporary pause on issuing awards that include a subaward to a foreign entity, and that they will renegotiate new, renewal or non-competing awards to remove subawards to foreign entities, and allow the funds to be re-budgeted for use by the prime recipient when the work can be performed domestically.

NIH has indicated that they will work with the recipient to negotiate a bilateral termination if a project is no longer viable without the foreign subaward, taking into consideration any need to support participant safety and/or animal welfare.

ORA recommends reaching out to active foreign subrecipients to notify them of the current situation.

No, NIH has indicated it will not retroactively revise ongoing awards to remove foreign subawards, but it is likely to occur before the next budget period is issued.

NIH defines a foreign component as the performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended. Activities that would meet this definition include, but are not limited to, (1) the involvement of human subjects or animals, (2) extensive foreign travel by recipient project staff for the purpose of data collection, surveying, sampling, and similar activities, or (3) any activity of the recipient that may have an impact on U.S. foreign policy through involvement in the affairs or environment of a foreign country. Examples of other grant-related activities that may be significant are:

  • collaborations with investigators at a foreign site anticipated to result in co-authorship;
  • use of facilities or instrumentation at a foreign site; or
  • receipt of financial support or resources from a foreign entity.

Foreign travel for consultation is not considered a foreign component. (See Grants to Foreign Organizations, International Organizations, and Domestic Grants with Foreign Components chapter in IIB).

When work is being done outside of the United States, whether or not grant funds are expended.

NIH is no longer accepting prior approval requests to add a new foreign componentor foreign subaward to an ongoing project.

NIH is no longer accepting prior approval requests to add a new foreign componentor foreign subaward to an ongoing project.