Uniform Guidance increases subrecipient monitoring responsibilities, limits each fixed price subaward to $150,000, and provides a 10% de Minimis F&A rate if a subrecipient does not have a negotiated rate.
Subrecipient monitoring and Uniform Guidance includes:
- increased scrutiny of the subrecipient F&A at the time of proposal, and increases emphasis on risk analysis prior to issuing a subaward;
- with prior approval, fixed price subawards of up to $150,000 are permissible under the Uniform Guidance;
- additionally, the Guidance clarifies that if a subrecipient does not already possess a negotiated Indirect Cost Rate, it may apply a de Minimis 10% rate (NIH at 8%)
The Uniform Guidance is effective for federally sponsored agreements and new funding increments awarded on or after December 26, 2014. Federal awards received before December 26, 2014 must continue to follow the requirements in OMB A-122 and Institutional Policy.
Through the OSP Subaward Commitment Form, MBL collects detailed information regarding a subrecipient’s F&A rate at the time of proposal. The Office of Sponsored Programs will review the subrecipient’s F&A rate to ensure compliance with the new requirements for entities that do not have a federally negotiated rate.
High risk subawards must be carefully evaluated and monitored through the life of the award, and additional oversight measures may be required depending on the experience level of the institution.