- Policy on Subcontracting on Sponsored Programs
- Processing Procedure
- Important Information
- Contact and Institutional Information
A subcontract - also referred to as a “subaward” - is a formal agreement between Northwestern University (Pass-through Entity, or PTE) and a subrecipient under a sponsored program. Most of the primary award terms and conditions will flow through to the subrecipient, particularly the regulatory requirements and obligations. The subaward agreement will also incorporate the subrecipient’s proposed scope of work and budget. Adjustments might be necessary if the prime award is reduced. Incoming subawards are categorized and handled as funded agreements. The following information applies to outgoing subawards.
Northwestern University Policy on Subcontracting on Sponsored Programs
When Northwestern University receives sponsored funding, it accepts the obligation to oversee work being performed by entities outside of the University. Subrecipients are assessed and categorized according to risk; subaward terms and conditions are written to address the corresponding level of risk. The prime sponsor holds Northwestern University responsible for the performance of work by subrecipients. Subrecipient monitoring enables Northwestern University to review scientific progress, expense allocation, and confirm that the subrecipient is performing according to the Principal Investigator’s programmatic needs.
All faculty and staff should become familiar with Northwestern University's Policy on Subcontracting on Sponsored Programs. The policy provides the framework on which subawards are issued, managed and closed during the lifecycle of a sponsored project. Also refer to faculty and staff Roles and Responsibilities in the context of subawards and sponsored projects administration.
Processing Procedure (for Establishing an Outgoing Subcontract)
- The sponsored award to Northwestern must be appropriated by OSR and the Project Account Summary (PAS) mailing received by the PI, research administrator, department chair or center director, and dean’s office.
- In consultation with the PI, the subcontract requestor (most commonly the research administrator) completes and submits a request to issue a new subcontract using the InfoEd change request (CR), subcontract module.
- OSR opens an Agreements screen in InfoEd, reviews the InfoEd CR subcontract request, conducts subrecipient risk assessment, drafts a subcontract agreement, and sends the agreement to subcontractor for institutional review and signature.
- Upon receipt of the partially executed agreement from the subcontractor, OSR conducts the final review. Once the review is complete, OSR provides the final signature on behalf of Northwestern University, fully executing the subcontract.
- OSR sends the fully executed agreement to the subcontractor and distributes the agreement locally to the subcontract requestor, OSR subcontract staff, and ASRSP subcontract staff.
- The departmental purchase order requestor works with ASRSP subcontract staff to establish a purchase requisition to encumber subcontract funds obligated in the Fully Executed Agreement (FEA). This step will enable ASRSP to pay subcontract invoices. For more information visit the ASRSP webpage on Subcontracts or contact ASRSP subcontract staff at ASRSP-Subk-EV@northwestern.edu or ASRSP-Subk-CH@northwestern.edu.
Status Updates: For individual subcontract requests, please view the Agreements tab in InfoEd for status updates. For a view of all pending subcontract requests for your department, run Cognos report GM055.
Sponsor Approval and Notice of Award (NOA) Terms: Prior sponsor approval requirements for adding new subcontracts are determined by the prime sponsor award. For FDP/RTC awards, please refer to the RTC Prior Approval and Other Requirements Matrix. When a subcontract is not included in the originally approved budget, please work with OSR to determine if sponsor prior approval is required. [NOTE: Not all sponsors require that the subcontract entity be listed on the NOA.] Download a copy of the Subrecipient vs. Contractor Classification Form here.
Subrecipient Commitment Forms: To download subrecipient commitment forms, visit the Tools & Forms page.
Financial Conflict of Interest (FCOI): For questions related to how FCOI is handled when a subcontract is included in a Northwestern proposal, please see the following references provided by the Northwestern University Conflict of Interest Office (NUCOI):
- Resources for Administrators
- Research Requirements for Subcontractors and Consultants (on PHS and NSF Grants)
- Institutions Verified by NUCOI with PHS & NSF-Compliant COI Policies [Note: NetID Login required for access]
Contacts and Institutional Information
For subawards on grants:
For subcontracts with industry
633 Clark Street
Evanston, IL 60208
Office for Sponsored Research
750 N. Lake Shore Drive, 7th Floor
Chicago, IL 60611