Subrecipient Guidance
The subagreement preparation and activation process is carried out by SDSU Research Foundation’s (SDSURF) Sponsored Research Contracting and Compliance (SRCC) department in consultation with the Prime Sponsoring Agency, Subrecipient, San Diego State University’s (SDSU) Principal Investigator, and various SDSURF and SDSU offices involved in policy and regulatory matters.
- Who prepares the subagreement and who can I contact regarding the status of the subagreement?
- What are the essential elements of a subagreement that a subrecipient must provide?
- Can the subagreement be issued before the prime award has been accepted and activated?
- What if the subrecipient does not have a conflict of interest policy consistent with the provision of 42 CFR Part 50, Subpart F?
- What if the Subrecipient does not have an IACUC or IRB?
- What is FFATA and when does it apply?
- How is the subagreement managed?
Who prepares the subagreement and who can I contact regarding the status of the subagreement?
The subagreement is prepared by SDSU Research Foundation’s Sponsored Research Contracting and Compliance (SRCC) department. See the SDSURF Directory (to find SRCC contacts). Once the initial process of preparation begins, SRCC will contact the subrecipient for essential elements required in order to process the subagreement.
What are the essential elements of a subagreement that a Subrecipient is required to provide?
- Subrecipient Commitment Form (hyper link to form) or Subrecipient Commitment Form for Modifications (hyper link to form)
- Copy of current F&A rate agreement (if applicable)
- Copy of Fringe Benefits rate agreement (if applicable)
- IRB approval/exemption notification (if applicable)
- IACUC approval/exemption notification (if applicable)
- Statement of Financial Interest and Conflict of Interest Training. If applicable, Statement of Financial Interest is required to be completed by subrecipient’s Principal Investigator and all key personnel. See SDSU’s Conflict of Interest Policy and Training for more information.
- Copy of or URL link to subrecipient’s most recently completed, independently audited financial statements Single Audit Act report of equivalent
- Current registration in https://sam.gov/content/entity-landing
- Data Universal Numbering System (DUNs) Number
- Federal Funding Accountability and Transparency Act documentation (if applicable)
- Current Insurance Certificates
- Vendor Information Form (PDF Format, 449KB)*
- W8-BENE or equivalent (if international)
- Not debarred or suspended
Can the subagreement be issued before the prime award has been accepted and activated?
The Subagreement process can begin, but subagreements cannot be fully executed by SDSU Research Foundation until the prime award has been accepted. See the award preparation and activation process for more information.
What if the subrecipient does not have a conflict of interest policy consistent with the provision of 42 CFR Part 50, Subpart F?
If subrecipient is required to have an active and enforced conflict of interest policy to be consistent with the provision of 42 CFR Part 50, Subpart F (add link) and the subrecipient cannot comply with this requirement, the subrecipient has the option to agree to abide by SDSU’s Conflict of Interest Policy.
What if the Subrecipient does not have an IACUC or IRB?
If the subrecipient does not have an IACUC or IRB, please contact SDSU’s Director of Research Affairs, Rick Gulizia, rgulizia@mail.sdsu.edu, 619-594-5938.
What is FFATA and when does it apply?
The Federal Funding Accountability and Transparency Act (FFATA) legislation requires information on federal awards and its first-tier subagreements be made available to the public via www.USAspending.gov.
The FFATA reporting system (FSRS) is the reporting tool Federal prime awardees use to capture and report subagreement and executive compensation data regarding their first-tier subagreements to meet the FFATA reporting requirements.
Federal Funding Accountability and Transparency Act (FFATA) applies to the prime recipient and their first-tier subrecipients if the Federal prime award is subject to Federal Acquisition Regulation clause 52.204-10 or is greater than or equal to $25,000 as of October 1, 2010.
For more information on FFATA requirements please visit www.fsrs.gov.
How is the subagreement managed?
See SRA Subagreement Procedures
*Note: Documents in Portable Document format (PDF) require Adobe Acrobat Reader 9.0 or higher to view. Download Adobe Acrobat Reader
