Per OSP Procedure, Principal Investigators (PI) initiate research collaborations by determining whether a collaborator is accurately defined as a Subrecipient or should instead be considered a Contractor (i.e. a Vendor or Consultant).

Subrecipients typically carry out intellectually significant portions of a project and will receive subawards from UVA via the Office of Sponsored Projects. Subaward agreements not only address the financial transaction required for the collaboration, but also address other award terms and conditions with which all subrecipients must comply.

Contractors, on the other hand, provide goods and services to UVA in support of a project, but as they are not involved in programmatic decision making, they are not subject to the same compliance requirements as subrecipients. Payment and contracting for contractor relationships is handled through Procurement.

Determining the correct type of collaboration for project partners at proposal stage helps ensure that appropriate costs and compliance requirements are accounted for. Failure to appropriately classify a collaborator may result in delays in award or subaward setup, inaccurate and insufficient project budgets, and can potentially result in audit issues if the appropriate review and monitoring procedures are not followed.

For assistance in making the correct determination, PI’s are encouraged to utilize the Federal Demonstration Partnership (FDP) Subrecipient or Contractor Determination Checklist. See Outgoing Subawards forms.

This document is UVA’s preferred method of confirming a subrecipient's intention to collaborate on a project. It obtains important information needed for proposal submission, as well details that are helpful at subaward preparation time. The current version of this form is available on the Outgoing Subawards page, under Forms.

If a subrecipient resists using the Consortium Commitment Form and wishes to confirm their intent to collaborate via an alternative documents, please contact OSP for further review.

A clearly defined SOW addresses the tasks to be performed by subrecipient personnel and the deliverables they will be responsible for. This is a key part of the subrecipient proposal package. While it may not be included in the proposal submission to the sponsor, the SOW goes hand in hand with the Consortium Commitment Form to make sure that both parties are on the same page regarding the nature of the collaboration.

A detailed, line-item budget reflecting the SOW and budget justification, or narrative further describing subrecipient costs, are required for each subrecipient.

The detail provided in the line-item budget and budget justification for each cost category must be sufficient to satisfy UVA expenditure monitoring and sponsor requirements. If the subrecipient is providing cost share as part of their project contribution, then a detailed budget and narrative for the cost share should be provided and an additional Letter of Commitment for the cost share is required.

See Subaward Budget Considerations for more information.

Other common documents from subrecipients that may be required include:

• Biographical Sketches of Key Personnel;
• Current and Pending Support of Key Personnel;
• Facilities, Resources, and Equipment Information;
• Representation and Certification Forms; and,
• Negotiated Indirect Cost Rate Agreements.

Policy and Requirements

As of January 1, 2024, NIH updated their subaward guidance to reiterate that all foreign subrecipients must provide access to copies of lab notebooks, data, and other documentation that support research outcomes described in project progress reports. These materials and data must be provided to the primary recipient with a frequency of no less than once per year, in alignment with the timing of progress report submission.

In support of this, UVA must obtain confirmation from potential subrecipients at the proposal stage that they understand and are willing to comply with the above requirements. The Consortium Commitment Form has appropriate language built in for these circumstances. Use of the form with foreign subrecipients is therefore strongly encouraged.

See the NIH subaward policy page for more information.

Data Storage

ITS, Research Computing, and OSP developed an onsite storage process and repository to help researchers fulfill data storage and audit requirements. With Globus, researchers can create collections where non-UVA associates and subrecipients can deposit project-related files, notebooks, etc. 

You can access Globus and obtain support in the NIH Grant Storage Requirements section at the bottom of the ITS Storage page.

Budgeting

Costs for meeting data storage requirements are allowable as direct project costs; therefore, we encourage departments to budget for these expenses when preparing for NIH proposals that involve collaborations with international subrecipients. Setup and per terabyte costs can be found on the ITS Storage page linked above.