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U.S. Department of Health and Human Services

Subrecipient Agreement Requirements

At a minimum, the subrecipient agreement must include the following:

  • Identification of the PI/PD and individuals responsible for the programmatic activity at the subrecipient organization along with their roles and responsibilities.
  • Procedures for directing and monitoring the programmatic effort.
  • Procedures to be followed in providing funding to the subrecipient, including dollar ceiling, method and schedule of payment, type of supporting documentation required, and procedures for review and approval of expenditures of grant funds.  A fee may not be paid by a recipient to a subrecipient/consortium participant, including a for-profit organization. However, a fee (profit) may be paid to a contractor providing routine goods or services under a grant in accordance with normal commercial practice. 
  • If different from those of the recipient, a determination of policies to be followed in such areas as travel reimbursement and salaries and fringe benefits (the policies of the subrecipient may be used as long as they meet HHS requirements).
  • Incorporation of applicable public policy requirements and provisions indicating the intent of the subrecipient to comply, including submission of applicable assurances and certifications.
  • For research subawards, inclusion of the following:
    • Statement specifying whether the financial conflict of interest requirements of the collaborating organization or those of the recipient apply.
    • Provision addressing ownership and disposition of data produced under the agreement.
    • Provision making the sharing of data and research tools and the inventions and patent policy applicable to the subrecipient and its employees in order to ensure that the rights of the parties to the agreement are protected and that the recipient can fulfill its responsibilities to the OPDIV. This provision must include a requirement to report inventions to the recipient and specify that the recipient has the right to request and receive data from the subrecipient on demand.
    • Provisions regarding property (other than intellectual property), program income, publications, reporting, record retention, and audit necessary for the recipient to fulfill its obligation to ASPR.

  • This page last reviewed: November 20, 2017