This page provides resources related to subawards. Please be sure to reference the NIH Grants Policy Statement (NIH GPS) and your specific notice of award for comprehensive requirements that apply to a specific award.
As outlined in the NIH GPS 1.2 , a subaward is 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 includes consortium agreements.
The relationship between the recipient and the collaborating organizations is considered a subaward relationship.
The NIH GPS serves as a term and condition of grant awards that applies not only to the prime recipients, but also flows down to any subawards unless specified otherwise in the regulation or the term and condition of the specific NIH award (See NIH GPS 15.1 ).
The primary recipient of NIH grant funds is accountable to NIH for:
The prime recipient must perform a substantive role in the conduct of the planned research and not merely serve as a conduit of funds to another party or parties. This includes being able to provide appropriate oversight of all scientific, programmatic, financial, and administrative matters related to the grant.
Setting up a Subaward (Consortium) Agreement
Must be done in partnership between the prime and subrecipient. The recipient must enter into a formal written agreement with each consortium participant, which must address all required elements.
The agreement must address the negotiated arrangements for meeting the scientific, administrative, financial, and reporting requirements of the grant, including those necessary to ensure compliance with all applicable Federal regulations and policies and facilitate an efficient collaborative venture.
The agreement must be approved by the Authorized Organization Representative at both institutions. When there a questions or concerns – contact the funding Institute or Center for support.
A subaward (consortium) agreement is:
NIH GPS 15.2.1 provides the detailed requirements for consortium agreements:
The prior approval requirements for change in scope and other significant changes to the project also apply to subrecipients. Since NIH’s legal relationship is with the prime recipient, subrecipients should contact the prime to request any prior approvals.
If a recipient (or consortium participant) proposes the transfer of work to a foreign site, NIH prior approval is required.
Effective January 2, 2024 , written agreements for foreign subawards must contain a provision requiring foreign subrecipients to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic.
By signing this subrecipient agreement, [Subrecipient name] agrees to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to [primary recipient] with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report described in [reference section of contract that provides timing of report submission]. [Subrecipient name] will make such data available via [insert recipient’s preferred method here (e.g., Sharepoint, Teams, Box, etc.)].
