Issuing the subaward

Follow SPA's standard procedure for issuing subawards.

UEI requirement for subrecipients — Subrecipients must obtain a Unique Entity ID (UEI) from SAM.gov. When the prime sponsor is federal, the subrecipient's UEI is required by federal award terms and is used for UMB's reporting to the federal government.

Export compliance. The SPA team will forward information about the proposed subaward to the export officer. The export officer reviews the proposed subrecipient and scope of work to ensure that no license or other U.S. government authorization is needed to proceed with financial transactions or sharing of research information.

Shipping of biological samples. If biological samples (including clinical samples) will be shipped internationally, a permit and/or license may be required in addition to a material transfer agreement for research materials. Contact Environmental Health and Safety for assistance reviewing U.S. and foreign regulations applicable to the shipment.

Animals and human subjects in research. If the foreign subrecipient’s scope of work involves human subjects research, work with the Human Research Protections Office. If the foreign subrecipient's scope of work includes animal research, work with the Office of Animal Welfare Assurance. These offices will help you to determine UMB’s requirements for compliance, documentation, and approval.

Agreement issues

Clear scope of work. The subrecipient’s scope of work must clearly describe what your collaborators are responsible for accomplishing if the award is made. Talk with your collaborators to ensure they understand your expectations, their roles and obligations, and specific sponsor and project requirements, especially milestones and deadlines.

Inclusion of award terms. Your award requires that certain terms and regulations be passed through to any subrecipient, whether domestic or foreign. SPA will determine whether the terms apply to the foreign subrecipient. Your foreign collaborator may need help with reviewing or interpreting sponsor policies and regulations.

Payment issues. In most cases, SPA will issue a subaward with standard, cost-reimbursement payment terms to our foreign subrecipient. However, if there are concerns — initially or as the collaboration progresses — regarding the subrecipient’s ability to meet project goals or to manage the funds in accordance with sponsor requirements, it may be possible to pay the organization based on milestones met. UMB's principal investigator (PI) can develop a schedule of project milestones, and fixed payments will be made only when the milestone has been met. Federal agency approval is usually required to issue a fixed-price subaward under a federal award. Contact your SPA team with any questions about fixed-price subawards.

Cash advances. Some foreign organizations are unable to move forward on the project without an advance of cash. If your collaborator requests a cash advance, SPA will review the request and determine whether and how to write an appropriate payment clause. Sponsor approval may be required.

Monitoring, invoices, and payments. Communicate with your collaborators. Set expectations and provide feedback. Make sure that:

• Invoices are received from the subrecipient.
• Progress is being made and the milestones are met.
• Invoice itemization including percent effort is sufficient and reasonably matches the approved budget.
• UMB's PI reviews and approves in writing all expenditures for work completed during the period stated on any invoice received.