Responsibility: KE Contracting Services
Prepared by: Subawards Functional Group
Updated: November 21, 2025
Review the additional tabs at the right for critical subaward information.
Subrecipient vs. vendor/contractor vs. consultant
On this page:
Federal Demonstration Partnership (FDP)
Requesting subawards post-award
Working with foreign subrecipients
Any questions regarding the information contained here can be sent to [email protected].
What is a subaward?
A subaward is a legally binding agreement issued when a substantive portion of the sponsored project will be performed by another entity. This sitelet discusses outgoing subawards meaning subawards that ASU issues to external entities.
ASU issues subawards to other entities when they are working in collaboration with an ASU Principal Investigator (PI) to perform a substantive portion of a grant or contract’s programmatic effort. To determine if ASU will need to establish a subaward, consult the Subrecipient vs. Vendor / Contractor vs. Consultant tool.
Most subawards are selected and proposed at proposal time.
Including named subawards in the proposal will help to expedite sponsor approvals. An awarded proposal that includes subrecipients constitutes sponsor approval of the proposed subawards.
Subawards should be clearly described in the ASU proposal and include as much detail as allowed by the funding announcement and page limitations. If the subaward should be issued as fixed price, this should be stated in the ASU budget justification. Including this secures sponsor prior approval to issue a fixed price subaward upon award, preventing an Award Change Request later.
To help prepare future subrecipients to receive an ASU-issued subaward, the Subawards Team recommends using the Subawards Welcome Packet found here.
Subrecipient scopes of work
The scope of work should not be a reiteration of the overall proposal being submitted. Rather it should define only the specific work to be performed by the subrecipient. Within this scope of work, it is important that the tasks to be performed are clearly outlined and that any expectations for reports or deliverables are listed.
The scope of work will become part of the legally binding sub-agreement. This document is the basis for determining the timeline for expected progress and how the research will move forward. If the scope of work is unclear, it can lead to confusion, misunderstandings, or grants that cannot/do not meet their objectives.
What is a sole source justification?
A sole source justification is an explanation of why a subrecipient is uniquely qualified for this particular project. Cost alone is not a satisfactory reason. It must also address the technical expertise of the Subrecipient PI.
It’s recommended that ASU PIs begin thinking about this justification at proposal time when selecting which subrecipients to work with. This information will later be outlined in a sole source justification form (either combined with a cost price analysis or individually submitted) necessary for audit compliance.
Below are some questions to consider when drafting the justification:
- What specific skills, unique expertise, and/or specialized facility does the subrecipient have?
- What makes this subrecipient the best (or only) fit for the project?
- What other sources were considered and why can’t they be used for this project?
Federal Demonstration Partnership (FDP)
The Federal Demonstration Partnership (FDP) is a group of federal agencies, research policy organizations, and academic research institutions with the goal of streamlining the administration of federally sponsored research.
The FDP manages a few key resources used at ASU:
- The FDP Expanded Clearinghouse. A single web-based repository for FDP entities to enter, upload, maintain and update all entity related information about their organization.
- Subaward templates. PDF-fillable templates used to issue subawards under federally-funded grants and cooperative agreements.
Subrecipient Letter of Commitment vs. Subrecipient Commitment Form
ASU has two subrecipient data collection forms depending on FDP membership status:
- Subrecipient Commitment Form. This form should be completed by non-member institutions.
- Subrecipient Letter of Commitment. This form should be completed by member institutions.
The abbreviated Subrecipient Letter of Commitment form can be used for member institutes because their institutional information and key contacts are included in the FDP Expanded Clearinghouse. For non-member institutions, the full length Subrecipient Commitment Letter allows critical subrecipient information to be collected for drafting a future sub-agreement.
What if we are submitting a proposal to a member organization and they request we complete their Subrecipient Commitment Form?
Review their subrecipient commitment form. If the form only requests completion of project specific information and not the administrative information contained in our FDP Expanded Clearinghouse profile, fill in the relevant section of the form. If the form requests additional, administrative information contained in our profile, send the following suggested language:
Arizona State University is a Participating Organization in the FDP Expanded Clearinghouse. The institutional profile can be found by selecting Arizona State University among the list of Participating Organizations. The data contained in the profile satisfies the requirements of the Subrecipient Commitment Form.
Types of subaward agreements
Depending on the type of prime award ASU receives, ASU will issue either a subgrant (under grant or cooperative agreement prime awards) or subcontract (under contract prime awards). The terms and conditions contained within will vary slightly depending on the type used, with subgrants referencing 2 CFR 200 (Uniform Guidance) regulations and subcontracts referencing the Federal Acquisition Regulations (FAR). subawards are issued as cost reimbursable or fixed price which reflects their overall payment mechanism. Beyond invoicing, all other terms and conditions largely remain the same.
A cost reimbursable agreement is based on actual project expenditures incurred during the performance period, up to an agreed “obligated” amount. The subrecipient budget reflects an itemized list of expenses, with a similar level of detail as the ASU budget, that they will expense against.
Fixed price agreements are issued when performance is based on deliverables, each of which is assigned a lump sum amount and a due date for when the deliverable will be completed.
Determining the type of subaward ASU will issue
Subaward payment mechanism is based on individual project factors. However, the following is illustrative of when it might be one type or the other:
| Cost reimbursement subawards | Fixed price subawards |
|---|---|
| The prime award made to ASU is cost reimbursable | The prime award made to ASU is fixed price |
| The subrecipient is a domestic entity | The subrecipient is a foreign entity |
| The subrecipient assessment risk level is low | The subrecipient risk level is high |
| The subrecipient is required to commit cost share | The subrecipient was proposed as fixed price at proposal time |
More information about how the Subawards Team determines the type of subagreement can be found here.
Subrecipient risk level
Each subrecipient is assessed for risk prior to the issuance of a subaward agreement. This process is jointly conducted by the Subawards Team and the Fiscal Operations Team (FOT). The Subawards Team assesses subrecipient risk at the project level while taking into consideration subrecipient institutional risk level assessed by FOT.
Reasons for a high-risk (or “not low risk”) designation include, but are not limited to:
Subrecipients where ASU will have limited visibility into the subawardee’s operations
Foreign entities that are governed by laws, regulations, and financial systems which do not align with the United States
Domestic entities with significant audit findings without a defined corrective action plan
Subrecipients without an external audit, internal control policies, or a sound financial system
Fixed price subawards
Approximately 10% of all subawards issued are fixed price. The other 90% are cost-reimbursable.
If the project team is aware that a subrecipient wishes to receive a fixed price subagreement at proposal time, the subrecipient should be identified as fixed price in the ASU proposal. This allows ASU to receive sponsor approval to issue a fixed price subagreement (required under 2 CFR 200.407) upon award.
Research Administrators (RAs) can specify the issuance of a fixed price subaward in the ASU budget justification.
The following language is recommended in the budget justification:
Note: Federal fixed price subawards may not exceed $500,000, including supplements and modifications, under 2 CFR 200.333. If the subrecipient’s work exceeds this amount, ASU will issue multiple subawards with separate and distinct scopes of work.
Requesting subawards post-award
If a subaward is required to carry out the project but was not budgeted in the proposal, sponsor prior approval will likely need to be obtained. This will depend on the prime award’s terms and conditions. Federal prime awards always require prior approval.
Regardless of whether prior approval is needed or not, the unit will need to submit an Award Change Request. After review, the Awards Management Team (AMT) GCO will forward the request to the sponsor. If no prior approval is required, the Award Change Request will trigger the establishment of a child account and subaward contract number (“ASUB” number) and the beginning of the subawards issuance process.
Note: More information about how the Subawards Team is notified of these changes can be found here. The following, at a minimum, should be attached to Award Change Request in ERA: Subrecipient Letter of Commitment (for FDP members) or Subrecipient Commitment Form (for non-members), subrecipient scope of work, and subrecipient budget/budget justification or payment deliverable schedule (if proposing fixed price). Other required subaward documents can be found under Subrecipient Information.
Working with foreign subrecipients
Working with foreign subrecipients can be challenging. They often do not have processes which parallel those in the United States. This may create difficulties completing the Subrecipient Commitment Form and other required subaward documentation. Working early with Contracting Service’s Subawards Team to determine what information will be required when the subrecipient does not have the same practices can save time and alleviate potential problems.
SAM registration and the Unique Entity ID (UEI)
In SAM.gov, entities have the option to either 1) receive only a Unique Entity ID (UEI) and not submit a full SAM registration or 2) submit a full SAM registration which includes receiving a UEI number. Most subrecipients will need to complete full SAM registration.
At a minimum, a UEI number is required for participating in projects funded by US government funds. Without a UEI number, ASU will be unable to report subrecipient funding under FFATA, a federally required reporting mechanism. While a UEI number is required, full SAM registration can often be waived for foreign subrecipients unless specifically required under the prime award.
Navigating the SAM registration process, even receiving only a UEI, can take up to six (6) weeks. It’s recommended that all subrecipients begin this process as early as possible to prevent delays.
One suggestion here is to help the foreign subrecipient’s administrative contact with the registration process by clearly explaining what they need to do to register. Navigating through United States’ regulations can be difficult for the foreign subrecipient and may lead to significant delays for the project. If the PI speaks their language, they may need to assist with translation.
Advanced payments
Foreign subrecipients generally need to be provided funds at the start of the project (sometimes called “start up funds”). Many do not have the ability to do the work prior to receiving these funds. To assist with this, foreign subawards can generally be issued a fixed price agreement where a portion of the funds (typically 10% of the total obligated amount) are issued upon execution of the subaward. The remaining funds would be issued based on a specific schedule of concrete deliverables. For this reason, it is critical that the scope of work be specifically worded to accommodate this type of arrangement.
Advanced payments can also be issued, on a case-by-case basis, under cost reimbursable subawards. This often allows project teams to more closely monitor project expenses while accommodating the subrecipient’s need to receive funds before completing the work. Under cost reimbursable subawards, multiple advanced payments can be issued throughout the life of the project.
Each request requires justification and must be approved by AMT. The standard amount eligible for advanced payments is 20% of the Year 1 budget or 20% of the total obligated budget. Subrecipients must spend 75% of the previous advance and provide an accounting report of the actual expenditures to ASU before additional funds can be advanced. However, the final 10% of the obligated amount may not be advanced. Additional terms and conditions will be included in the subaward to accommodate this request.
FAQs from the RA Community
The Subawards Team uses ERA tasks to managing tasks and overseeing workload across the team. Once an Award Change Request is completed, ERA automatically generates a task request and notifies the [email protected] inbox for assignment. To avoid duplicate tasks in ERA, its recommended not to create an additional task when an Award Change Request is in progress. More information about how the Subawards Team assigns tasks can be found here.
However, if there is available capacity and the subawards modification is considered a rush, a subaward modification agreement may be drafted outside of ERA for quicker execution upon receipt of the Award Change Request completion. These instances should be discussed directly with the Subawards Team by contacting [email protected] and will be managed on a case-by-case basis.
Once a new subaward task is assigned, the Subawards GCO will reach out to the RA Contact listed to request all missing documentation, including the CPA and SSJ. Subawards GCOs work with the RA first to collect any missing documentation before reaching out to the subrecipients or PIs respectively. However, RAs can always request for the Subawards GCO to work directly with a subrecipient or PI to collect the missing information and documentation instead if this is preferred.
Additional information can be found under Roles and Responsibilities.
All documentation and registrations should be received before a subagreement is drafted and sent to subrecipients for review. However, for some RUSH tasks, Subawards GCOs may elect to draft and send the subagreement for review prior to receiving all documentation such as the cost price analysis, sole source justification form, or PaymentWorks registration. If a subaward is sent to the subrecipient prior to receiving all documentation, the missing documentation and registrations are requested with the subagreement. Subaward agreements need to be approved by the ASU PI before they can be reviewed by a subrecipient.
Additional information can be found under During Award.
ASU cannot issue a subaward agreement prior to receiving a fully executed prime award. This is for a few reasons:
- ASU cannot issue a subaward without prime award terms and conditions to flow down to our subrecipients. The subaward would be incomplete.
- Issuing subawards prior to receiving an award invites risk to the University and the unit.
Additional information can be found under During Award.
Yes, the subrecipient’s period of performance can differ from ASU’s as long as the start and end dates fall within ASU’s obligated award period. ASU cannot issue subawards outside of our own period of performance.
Absolutely! The assigned Subawards GCO would be happy to help the subrecipient with any questions they have related to the subawards process, the required documentation and registrations, and clarifications on the subagreement itself. If there is a question than an RA or PI does not feel comfortable with answering, the Subawards GCO should be connected to work with the subrecipient directly.
This depends on the prime award terms and conditions as well as the subrecipient’s agreement type.
If the subrecipient was issued a fixed price subaward, all payments will be issued upon completion of a set list of deliverables. Budget detail in this type of subagreement is limited to lump sum deliverable amounts rather than the line item budgets used in cost reimbursable subagreements.
For federal subawards, post-award RAs should review the prime award terms and conditions as well as any relevant FAR or 2 CFR 200 guidelines regarding budget revisions to make this determination.
ASU does not currently require proof of research security training completion prior to subaward execution. Subrecipient institutions should manage research security training compliance, as outlined and required under the subagreement and prime award, within their own institutional practices.
Please reach out to the Subawards Team by emailing [email protected] and providing the below information:
- AWD number
- Subaward contract number (i.e., ASUB number)
- ERA subaward task ID (if known)
- Justification for why the task should be considered a RUSH
A team member will review, and assign based on team capacity for additional RUSH tasks and internal guidance. Limiting the number of tasks considered rushes enables the Subawards Team to attend to all RUSH items in a timely manner and truly process them with an expedited timeline.
The Subawards Team may consider a task a RUSH item depending on several internal factors including team capacity for additional RUSH tasks, institutional risk considerations, institutional priorities, and more. Please reach out to the Subawards Team at [email protected] to discuss any pertinent details related to your subaward and the task will be categorized accordingly.