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Working with Subrecipients / Subrecipient Forms / Letter of Commitment
Quick Links to Forms
- Subrecipient Statement of Collaborative Intent/Letter of Commitment (the "Subrecipient Form" or the "LOC" form)
- Attachment 3B
Working with Subrecipients
A subrecipient may be either a formally-designated project in which the direct sponsor receives funds from a prime sponsor or an arrangement in which U-M provides funds for performing part of a project to another organization.
Other "Sub" Terms
- A subrecipient (or subawardee) is arranged for with a subcontract (sometimes called SubK).
- A subcontract provides for funds to perform part of a project as a collaborator or co-Principal Investigator.
Are you working with a Subrecipient or a Contractor? Knowing the difference impacts indirect costs and unit budgets.
At U-M, knowing the difference impacts indirect costs as well as whether your project is handled by the Office of Contract Administration or Procurement. To be sure, visit our Subawards, Hybrid Agreements, and Purchase Orders page.
Also see the FDP Checklist to Determine Subrecipient or Contractor Involvement -- a useful resource from Federal Demonstration Partnership to help determine Subrecipient versus Contractor involvement.
Subrecipient Forms
Letter of Commitment / Subrecipient Statement of Collaborative Intent
A completed Subrecipient Form is required when requesting a subcontract if the sponsor of the PAF/parent project follows the PHS financial conflict of interest (FCOI) regulation. Use the template below to collect the information from the subrecipient institution that U-M needs to establish the subcontract, including their COI Policy Certification option.
Please note, the University of Michigan participates in the Federal Demonstration Partnership (FDP) Clearinghouse where you can look up subrecipient information. For U-M information, ask institutions to check that first.
Subrecipient Statement of Collaborative Intent/Letter of Commitment.
If the project sponsor follows the PHS FCOI regulation and the subrecipient institution elected that U-M review for potential FCOI in the Letter of Commitment, each subrecipient investigator must disclose outside interests to U-M prior to subcontract activation. Use the "Non-U-M Affiliate Disclosure Form" below to obtain completed disclosures.
All subrecipients, as well as potential subcontractors who anticipate funding under a federal or non-federal contract, should complete this form when participating as a subrecipient or subcontractor in a proposal submitted by U-M. This form provides a checklist of documents and certifications required by prime sponsors, and if it is completed, it must be endorsed by the subrecipient’s authorized institutional representative prior to proposal submission.
Financial Interests Disclosure Form for Investigators Not Affiliated with U-M [fillable .doc]
If the project is funded under a federal contract, then additional Cost/Price Analysis information is needed.
Procedure to Obtain a Subaward or Hybrid Agreements
For questions regarding whether the collaboration involves a subrecipient, contractor, or hybrid agreement, please contact the Office of Contract Administration (OCA) at subcontracts@umich.edu.
The procedure to obtain a subaward/subcontract or a hybrid PO from Office of Contract Administration begins in eResearch Proposal Management (eRPM). For full system instructions:
Enter a Subcontract Procedure in eRPM [PDF]
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Note: If an existing PAF (in a non-Active state) that includes a subcontract requires editing you will also need to follow the Subcontract process outlined above to complete the Subcontract worksheet and re-route the PAF for unit or ORSP approval
To add a NEW subcontract to an awarded project, start the process from the Subcontracts tab in eRPM.
To change an active subcontract (e.g., extend funding, update investigators, initiate an early close):
NIH Updates for Subaward/Consortium Written Agreements
A reminder that, effective January 1, 2024, NIH’s Policy Guidance for Subaward/Consortium Written Agreements, requires international subrecipients to provide access to copies of all lab notebooks, all data, and all documentation that support the research outcomes as described in the progress report to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report (RPPR) submission.
Principal Investigators on NIH projects with foreign subrecipients must ensure that access to such lab notes, data, etc, is provided in alignment with the timing of RPPR submissions. Cases of subrecipient non-compliance must be reported to Subcontracts@umich.edu.
NIH will not support any agreement that does not meet the minimum requirements outlined in this notice.
The Office of Contract Administration (OCA) and the Office of Research and Sponsored Projects (ORSP) have worked together to update the subrecipient form / letter of commitment (LOC).
Additional Resources: NOT-OD-23-182, Subawards, FAQs, or contact us at Subcontracts@umich.edu.