A subaward (also referred to as a subgrant or subcontract) is an award of financial support from a prime awardee (e.g., Yale) to a qualified organization for the performance of a substantive portion of the programmatic effort under the prime award. The term also includes awards made by a subrecipient to a lower tier subrecipient. It does not include procurement of goods and services purchased under an award, as the providers of these goods and services have no programmatic responsibility.
Per section B of Procedure 1307 PR.01, “the Principal Investigator, with help from their department business office, is responsible for obtaining a completed Subrecipient Information and Compliance (SIC) Form, signed by the subrecipient’s authorized representative along with supporting documentation, as applicable, prior to the submission of the proposal to OSP.”
Additionally, the Policy states that “proposals may not be submitted to a PHS agency, a PHS-like sponsor, or the NSF without certification from the subrecipient that it has a compliant policy and has made all required disclosures”. It is the responsibility of the department business office to provide the subrecipient with the Yale model PHS compliant policy and model disclosure form for the subrecipient to adopt.
Faculty and staff who are involved in the issuance and/or monitoring of subwards are encouraged to attend the Subrecipient Basics and Monitoring training. The two-hour course addresses the difference between subawards and procurement actions, requirements for establishing and monitoring subawards, and roles and responsibilities of the PI and administrators throughout the subaward process.