|Policy Approval Authority
|Division of Research and Innovation Partnerships
|Responsible University Office
|Sponsored Programs Administration
|Assistant Vice President for Research and sponsored Programs
|Dara Little, email@example.com
|Effective Adoption Date
|Last Review Date
Sponsored Funding/Grants and Contracts
To provide guidance regarding NIU’s monitoring and stewardship obligations when transferring a portion of sponsored work to another organization.
NIU Principal Investigators (PI) may need to collaborate with colleagues at other institutions or organizations to enhance scientific or programmatic aspects of a research project or because a funding solicitation encourages multiple organizations to participate together.
These collaborations often require NIU to transfer a portion of the sponsored project funds and scope of work to a collaborating institution. Under this arrangement, the collaborating institution becomes a “subrecipient” to NIU and becomes responsible for its portion of the award. Federal regulations ultimately hold NIU accountable for the subrecipient programmatic and fiscal performance. NIU’s inability to properly classify an entity as a subrecipient and effectively monitor these agreements can result in disallowed costs or loss of funding.
Pass-through entity 2 CFR §200.74: Pass-through entity means a non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program. In the context of this policy, NIU is the non-Federal entity.
Subrecipient 2 CFR §200.93: Subrecipient means a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. A subrecipient
may also be a recipient of other Federal awards directly from a Federal awarding agency. In the context of this policy, the collaborating institution is the subrecipient.
Subaward 2 CFR §200.92: Subaward means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. The term subaward is used to describe the agreement that NIU will issue to the collaborating institution to transfer funding for the collaborator’s portion of the project.
Contractor 2 CFR §200.23: A contractor is an entity that receives a contract as defined in §200.22 Contract (see Contract below).
Contract 2 CFR §200.22: Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award. The term as used in this part does not include a legal instrument, even if the non-Federal entity considers it a contract, when the substance of the transaction meets the definition of a Federal award or subaward. The term contract is used to describe vendor or professional services needed for a sponsored award.
The below characteristics are a guide only. Ultimately, the substance of the relationship is most important when classifying an entity as a subrecipient or contractor.
These are the characteristics of a subaward. The subrecipient:
These are the characteristics of a contract. The contractor:
NIU will manage subrecipient agreements in accordance with 2 CFR 200.330 and 200.519, university policies, applicable sponsor regulations, and the terms and conditions of the sponsor award. As the pass-through entity, NIU remains responsible for the transfer of funds to a subrecipient and for meeting all projects' performance goals.