Planning Considerations for Subawards

When a sponsored project involves collaboration with an external investigator or organization, a Subaward may need to be established. There are many planning considerations for initiating a successful subaward, including (but not limited to) these areas.

Subaward Risk Level: Risk Assessment

The university conducts annual risk assessments of all subrecipients to ensure they can responsibly manage funds and meet project objectives, as required under GW’s Subrecipient Monitoring Policy. These assessments are carried out by Grants and Contracts Accounting Services (GCAS), which reviews financial health, prior performance, and administrative capacity to assign a risk level. Subrecipients may receive regular approval if they pose low risk, conditional approval if elevated risks are identified, or in some cases a high‑risk designation. The assigned risk level influences subaward terms, such as reporting frequency, invoicing requirements, or tailored conditions for high‑risk subawards. The Office of Sponsored Programs (OSP) Subaward Team ensures that valid risk assessments are on file before issuing or modifying subawards, incorporates risk‑related terms into agreements, and coordinates internal kick‑off meetings for conditional and high-risk approvals. School Research Teams support this process by gathering required information from subrecipients and monitoring compliance with invoicing, reporting, and any additional risk‑related requirements throughout the life of the subaward.

Subaward Payment Mechanisms

Subrecipient payment mechanisms refer to the method by which payments are made to a subrecipient for work performed under a statement of work. The two primary mechanisms are:

• Cost Reimbursable Agreements: Under this mechanism, the subrecipient is reimbursed for actual, allowable costs incurred, provided that such costs are explicitly described in the Agreement. To support effective monitoring throughout the invoicing process, cost reimbursable agreements should include a detailed scope of work along with a comprehensive budget and justification. Cost reimbursable agreements establish a financial ceiling, which the subrecipient may not exceed - except at its own risk - without a formal modification. This funding method is widely used in collaborative research agreements, and is typically the best approach when deliverables are intangible or difficult to quantify, such as when project outputs consist of progress reports, or other non-material results, which are common in grants and cooperative agreements.
• Fixed Amount Agreements - also referred to as firm-fixed price, firm-price or fee-for-service in a subcontractor context – provide for payment of predetermined amounts tied to the successful completion of deliverables or milestones, regardless of the actual costs incurred.  Fixed amount agreements are best suited for smaller, discrete contributions where outcomes are clearly defined, measurable, and verifiable, and where the subrecipient operates independently. They are not recommended for complex collaborations or projects with evolving deliverables.  Fixed amount agreements must include a well-defined scope of work, clearly articulated deliverables or milestones, and, where applicable, a delivery schedule. The budget outlines specific payments for each deliverable and must be based on a solid estimate of costs that aligns with sponsor requirements. This funding method is most appropriate when project risks are low and deliverables are well-defined and predictable, for example, where tangible, measurable outputs can be easily verified. Fixed price agreements often require sponsor approval and, when federally funded, must remain within the threshold stipulated by the sponsor, which may vary depending on the funding source.

Conflict of Interest (COI) Requirements for Subrecipients

Federal regulations require that the university flow down sponsor Conflict of Interest (COI) requirements to all Subrecipients.  Most Subrecipients maintain institutional COI policies that comply with federal agency requirements. In such cases, the Subrecipient follows their own policies and certifies compliance with sponsor requirements by executing the Subaward.

If a Subrecipient does not have a compliant COI policy, they may elect to follow GW’s COI Policy, available on the Office of Research Integrity & Compliance (ORIC) website.  Subrecipients adopting GW’s policy must adhere to the same requirements as GW personnel, including completion of a Financial Conflict of Interest (FCOI) disclosure and, where applicable, compliance training via the University’s CITI platform.

Human Subjects Research

When a subrecipient will be conducting work involving human subjects, Institutional Review Board (IRB) approval must be obtained prior to initiating any such activities. The university requires that IRB approval documentation be available upon request.

Animal Studies

When a subrecipient will be conducting research with vertebrate animals, appropriate approval must be secured before beginning the work. The university requires that documentation of this approval be available upon request. In addition to the Subaward Agreement, the university also requires an Animal Memorandum of Understanding (MOU) between the subrecipient and the university. This MOU is initiated by the OSP Subaward Team and executed by ORIC.

Other Compliance Requirements

When a subrecipient will be conducting work involving regulated materials or activities -such as biohazards, radioactive substances, or other compliance‑sensitive research - appropriate approvals must be obtained prior to initiating the work. The university requires that documentation of these approvals be available upon request to ensure compliance with applicable federal, state, and institutional regulations. In addition to the Subaward Agreement, supplemental memoranda of understanding or certifications may be required, which are coordinated by the OSP Subaward Team and executed by the Office of Research Integrity & Compliance (ORIC).

Frequently Asked Questions

Who initiates the subrecipient risk assessment?

The OSP Subaward Analyst requests the risk assessment from GCAS. The Department assist in gathering the required information from the Subrecipient, as needed.

What financial documents are required from the subrecipient for the risk assessment?

If the subrecipient participates in the FDP Clearinghouse, the most recent Single Audit is typically sufficient. If no audit is available, other externally audited financial documentation must be provided. GW’s financial questionnaire is always required for for-profit entities and may also be requested from others if the available financial documentation is insufficient for risk assessment.

Do for-profit subrecipients require a risk assessment?

In accordance with GW’s Subrecipient Monitoring Policy, a risk assessment is required for all subrecipients. For-profit entities must submit the GW financial questionnaire along with other financial documentation as part of this process.

Do I need a risk assessment for a no-cost extension or other non-monetary modification to a subaward?

Yes. A valid risk assessment must remain on file as long as a the subaward is active, regardless of whether the modification involves additional funding.

When should I use a cost reimbursable agreement? 

Use cost reimbursable agreements when deliverables are intangible, the scope may evolve, or outcomes are difficult to quantify—common characteristics of grants and cooperative agreements. This funding mechanism is especially suited for longer-term projects, larger budget agreements, and collaborative efforts in which the prime recipient and subrecipient jointly develop and contribute to project outcomes.

When should I use a fixed amount agreement? 

Fixed amount agreements may be appropriate when the subrecipient’s contribution is smaller and independent, and when outputs are clearly defined, measurable, predictable, and low-risk.

Do I need sponsor approval if the fixed amount subaward was included in the proposal? 

No. If the fixed amount subaward was included in an approved proposal, it is considered approved by the sponsor.

What kind of deliverables are suitable for fixed amount subawards? 

Suitable deliverables should be:

• Tangible - result in a concrete product (e.g., training completed, data set delivered, 5-page evaluation report submitted)
• Discrete - stand alone as a clearly defined unit of work
• Time-bound - include a due date or timeline to guide monitoring progress
• Verifiable - documentable and able to be reviewed for completeness and quality
• Linked to Payment - clearly tied to a fixed payment amount in the agreement.  Multiple checkpoints or deliverables must be present for monitoring.

Is a risk assessment required for a fixed amount subrecipient?

Yes, a risk assessment is still required to determine the appropriate level of monitoring and oversight.

Is detailed cost tracking required under fixed amount agreements? 

No. However, the initial budget must be based on a reasonable cost estimate, and completion of deliverables must be well documented.

Support

• Office of Sponsored Project Teams