Procedure Library

NSF Adding Subrecipient Institution

Purpose

To clarify the steps needed when the University needs to add a subrecipient institution after the award has been issued.

This may happen when the University PI determines they need additional resources or expertise that's only available through a new subaward arrangement that wasn't originally foreseen and proposed. 

Even when the University is involved in a NSF collaborative project, NSF's recommendation is commonly for the University to handle the administrative changes. This involves obtaining NSF prior approvals and issuing a subaward to the new subrecipient.

Applicability

As stated in the PAPPG 23-1, NSF requires that no portion of an activity be subawarded or transferred to another organization without prior written NSF Authorization.

Instructions

PI's should inform their Sponsored Projects Officer of their interest to establish a new subcontract as soon as possible and work with their admin, if available, to complete the process outlined below. 

OSP should work with the PI to obtain a rebudget and verify whether the project activities are more appropriate for the role of contractor/vendor or subrecipient (see the Procedure on Determine Subrecipient or Vendor) and if the rebudget will cover the F&A on the first $25k of the subaward.

eAward:

1. PI's, or their admin, should initiate a "New Subaward Setup" request in eAward:
   
   
   1. OSP encourages close coordination with their SPO so that, while the University of Utah is obtaining NSF formal approval, the new subrecipient can use this time to complete and certify the Subrecipient Information needed to draft the new subaward.
   2. If NSF approval is still pending when the Subrecipient Information is certified, the SPO can use the time to draft the subaward (with the Contract Administrator) but OSP will need to iconHOLD the fully executed version until OSP has received NSF prior approval and has processed the necessary rebudget. 

Research.gov:

Please be aware that NSF Other Authorized User (OAU), unlike with proposals, cannot be given permissions to edit these post-award requests. Therefore,  SPO's should expect to perform more manual entry when working on this type of requests. 

1st Request - New co-PI

1. Before PI's can create the 'Subawarding, Transferring or Contracting Out Part of an NSF Award' request, they will need to create (and have approved) the 'Substitute (Change) PI/PD or co-PI/co-PD request'. 
2. Here the PI will propose a co-PI for the new subrecipient.
   • The proposed co-PI will need to have  and provide the University of Utah with thier NSF account ID.
3. PI's will start the NSF approval process by preparing a new Notification/Request in Research.gov and clicking 'Prepare New'. 
   
   
4. They will be asked the following questions:
   
   1. Step 1: Select type of change -  'Other'
   2. Step 2: Select notification/request 'Changes in PI/PD, co-PI/co-PD or Person Months Devoted to the Project at the initiation of the Grantee Organization'
      
      
5. OSP will need the proposed Co-PI's NSF ID, institutional email address, and institutional UEI to initiate the request.
6. Required senior personnel documents for the proposed co-PI include:
   1. Biographical Sketch in NSF format
   2. Current and Pending Support in NSF format
   3. Justification for the request (including impact on the project)
      1. This should be a short explanation. e.g.: "The University of Utah is attempting to submit a request to add ____ as a subrecipient. As part of this effort, we are requesting to add ______ as a co-PI. Dr. ____ will be PI on the new subaward. Once approved, we can submit the formal request for subawarding out."
7. Once the request is complete, the PI will need to route the request to the SPO/AOR for review and submission. 
8. Please allow 4-12 weeks for NSF processing. Once a determination is made, the Status will be updated and, if approved, the University of Utah PI can initiate and complete the 2nd request.

2nd Request - New Subaward

1. PI's will start the NSF approval process by preparing a new Notification/Request in Research.gov and clicking 'Prepare New'. 
   
2. They will be asked the following questions:
   
   1. Step 1: Select type of change -  'Other'
   2. Step 2: Select notification/request 'Subawarding, Transferring or Contracting Out Part of an NSF Award'
      
   3. Step 3: Enter award number and click 'Prepare new'.
3. The PI will select the corresponding award number from the drop-down list and click 'Prepare New':
   
4. Per the NSF PAPPG 23-1, the PI will need to upload & submit the following:
   1. Description of Work to be Performed - a clear description of the work to be performed by the new subrecipient. This can be the same SOW as originally proposed, or as attached in the subaward, but with any references to the exiting institution replaced with the new institution. 
   2. Budgets (Including Budget Justifications)
      1. a separate University of Utah budget and budget justification in NSF format
         1. The University of Utah budget should reflect the awarded F&A rate
      2. a separate Subrecipient budget and budget justification in NSF format, using the new institution's federally negotiated F&A rate
         1. The new subrecipient should use that institutions federally negotiated F&A rate for the budgeted timeframe. 
   3. Justification for Subrecipient - see template.
   4. Other Supplementary Docs - if applicable. 
      1. if funding is requested to support a postdoctoral researcher, and the original proposal did not include a mentoring plan, then the request must include the requisite mentoring plan as described in chapter II.C.2.j. The plan must be uploaded under "Mentoring Plan" in the Supplementary Documentation section of Research.gov
5. Once the request is complete, the PI will need to route the request to the SPO/AOR for review and submission. 
6. Please allow 4-12 weeks for NSF processing. Once a determination is made, the Status in Research.gov will be updated. 
   1. If the request is declined, it's likely that the request was submitted incorrectly or was incomplete. The status in Research.gov will show as 'Rejected by PO'. If the SPO or PI is unclear why it was rejected, please contact Laurel.
   2. If the request is approved, the status will be updated to 'Approved by Grants Official' and a new modification will be issued formally authorizing the new subrecipient:
      
7. Once received, the NSF approval should be uploaded into the eAward subaward transaction. icon At this time, the SPO can proceed with the issuing of the new outgoing subaward and its purchase order.
8. Once the process is complete, the eAward transaction status in eAward will be marked 'Completed'.

eAward

1. Finally, PI's, or their admin, should initiate an "Award Modification" request in eAward using the NSF approval:
   
2. Select the Budget Revision/Rebudget option:
   
3. Complete the rebudget process as normal.
4. Once there are funds available for the subaward, OSP can complete the subaward and purchase order processing.
   
   

Related Policies and Procedures

• Grant Life Cycle > Manage Your Award
• Grant Life Cycle > Manage Your Award > Expanded Authority Actions