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Note: Project teams still need to obtain a generic letter of commitment or a PHS letter of commitment, as applicable, even when our subrecipient is registered in the FDP pilot clearinghouse.
Current/Old Forms (to be phased out January 6, 2020):
- 1. Letter of Commitment to Establish a Subrecipient Agreement
Non-U-M Affiliate Disclosure Form
- 2. Letter of Commitment to Establish Subrecipient, where U-M is Subrecipient
Used when U-M is the subrecipient, and the institution making the subcontract needs information about U-M but doesn't have their own institutional forms. Note: you can use this template to establish a subcontract on a project with any sponsor, but the COI Policy Certification may not apply.
- 3. Subrecipient Statement of Collaborative Intent. (Note: We will transition to this form on January 6, 2020. For now, you can use either this or the soon-to-be-retired Letter of Commitment forms.)
The University of Michigan (U-M) is participating in the Federal Demonstration Partnership's (FDP) Expanded Clearinghouse Pilot 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 generic letter of commitment or a PHS 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 us has to send or require complete 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)”