For determination of Subaward vs. Contractor relationship at the proposal stage, see the OSP Subrecipient vs. Contractor Guidance.
Subaward Proposal Development Tips (Collecting Information):
What documentation is needed from a subawardee at the New or Renewal application stage?
ORA 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)
Additional documents commonly collected:
- Biosketch or CV, as applicable, for all key personnel
- Facilities & Other Resources
- Equipment, if applicable
- Letters of support, if applicable
Other documents that may be required (review sponsor guidelines carefully and discuss with your ORA representative as needed):
- IACUC, IRB, or other project approvals - some sponsors require these at proposal stage
- Other Support/Current & Pending Support for key personnel
- Representations and Certifications (for federal contract proposals)
- If the prime award is a federal contract, subcontracts that will exceed $700,000 (total costs over the entire project period) may need to submit a Small Business Subcontracting Plan, per FAR 52.219-9.
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 Statement of Work?
- Verify subawardee’s indirect cost rate.
- For subawards outside the U.S. under NIH awards, NIH allows F&A costs for foreign and international organizations at a fixed rate of 8% of modified total direct costs (MTDC), exclusive of tuition and related fees, direct expenditures for equipment, and subawards in excess of $25,000.
- For subawardees without a federally negotiated rate, consult ORA.
- Work with collaborating institution's administration to address any questions or concerns.
Factoring Subaward costs into Harvard’s F&A Base (Federal Funds):
- For federal proposals, the first $25K of the subawardee’s total costs (the “cap”), may be included in the School's MTDC.
- If the subaward's total costs (TC) in year 1 are less than $25K, then the School's F&A for the 2nd year must include the balance.
- Note the $25K cap routinely applies to Federal awards. Some 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 (TDC).
Federal and Non-Federal Funds:
- The Subawardee’s total costs (direct costs + their F&A) are part of the School’s direct costs.
- 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 or if prior approval is needed to submit an application requesting $500k or more in direct costs in any one year.