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U-M as a Subrecipient
Avoid the unnecessary completion of subrecipient forms with U-M information. U-M provides that in our FDP Clearinghouse profile.
Typically a DUNS number is required to view it. We share that on ORSP's home page.
Note: Project teams still need to obtain a generic letter of commitment, even when our subrecipient is registered in the FDP pilot clearinghouse.
The University of Michigan (U-M) participates in the Federal Demonstration Partnership's (FDP) Expanded Clearinghouse for Subrecipient Entity Monitoring.
U-M is Part of FDP Subrecipient Expanded Clearinghouse
The purpose of this effort is to reduce the administrative burden associated with verifying standard information for each and every subaward between institutions when acting as either a Subrecipient or a Pass-Through Entity.
Instead, institutions like U-M will enter, upload, maintain and update an Entity Profile with information about their organization. Universities participating in the pilot have agreed that we will not exchange forms and information since it will be accessible via the web-based Entity Profiles.
You will still need to collect some institutional agreement to participate at the time of proposal. As the FDP website states, "Minor exchanges of data that are transaction/subaward specific (such as an IRB approval, Statement of Work or budget) may still be shared between the pass-through entity and the subrecipient, provided that such exchanges do not require completion of data already appearing on the entity's published profile." *
For example: Project teams still need to obtain a letter of commitment, as applicable, even when our subrecipient is registered in the FDP pilot clearinghouse.
How does it affect Research Administrators?
Here are some steps you can take and language you can use when we are either the Pass-through entity or the Subrecipient:
When we are the Pass-through Entity:
Check first. Do not collect a Subrecipient Commitment Form from another participating pilot institution. Just visit this resource to look up the profile information for the subrecipient you need.
When We are the Subrecipient:
Kindly explain and do not complete a Subrecipient Commitment Form for a pass-through entity participating in the pilot. Instead; please remind the other institution that we are part of the Expanded Clearinghouse pilot. Here is some sample language to include in your documentation:
“Our organization participates in the FDP Expanded Clearinghouse. You can find our profile information here: https://fdpclearinghouse.org/organizations/95. This will reduce administrative burden so that neither of our institutions has to send, complete, or require a subrecipient commitment form.”
If pressed, here is some sample "pushback" language:
“I am writing to let you know that the University of Michigan is a pilot participant in the FDP Expanded Clearinghouse. It is my understanding that your organization is also a pilot participant. As a part of the pilot, both our organizations have agreed that we will not send or require completion of a subrecipient commitment forms, but will instead use our profile that is posted on-line at the FDP Expanded Clearinghouse site (https://fdpclearinghouse.org)”