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Issuing the subward
Export compliance. An extra review step is added to SPA's standard procedure for issuing subawards. ORD's export compliance officer reviews the proposed subrecipient and scope of work to ensure that no license or other U.S. government authorization is needed to proceed with either financial transactions or sharing of research information.
Shipping of biological samples. If biological samples (including clinical samples) will be shipped internationally, a permit and/or license may be required in addition to a material transfer agreement for research materials. Contact Environmental Health and Safety for assistance in reviewing U.S. and foreign regulations applicable to the shipment.
Animals and human subjects in research. If the foreign subrecipient’s scope of work involves human subjects research, work with the Human Research Protections Office. If the foreign subrecipient's scope of work includes animal research, work with the Office of Animal Welfare Assurance. These offices will help you to determine UMB’s requirements for compliance, documentation and approval.
Clear scope of work. The subrecipient’s scope of work must clearly describe what your collaborators are responsible to accomplish if the award is made. Talk with your collaborators to make sure they understand your expectations, their roles and obligations, and specific sponsor and project requirements, especially milestones and deadlines.
Legal party. SPA will confirm the legal party to the agreement, which is normally the organization that completes the Subrecipient Commitment Form.
Inclusion of award terms. Your grant or contract requires that certain terms and regulations be passed through to any subrecipient, whether domestic or foreign. SPA will determine whether the terms are applicable to the foreign subrecipient. Your foreign collaborator may need help with accessing and/or interpreting policies and regulations.
Payment issues. In most cases, SPA will issue a subaward with standard, cost-reimbursement payment terms to our foreign subrecipient. However, if there are concerns – either initially or as the collaboration progresses – regarding the subrecipient’s ability to meet project goals or to manage the funds in accord with sponsor requirements, it may be possible to pay the organization based on milestones met. UMB's PI can develop a schedule of project milestones, and fixed payments will be made only when the milestone has been met. Federal agency approval may be required to issue a fixed price subaward under a federal award.
Cash advances. Some foreign organizations are unable to move forward on the project without an advance of cash. If your collaborator requests a cash advance, SPA will review the request and determine whether and how to write an appropriate payment clause. Sponsor approval may be required.
Monitoring, invoices and payments. Communicate with your collaborators. Set expectations and provide feedback. Make sure that:
- Invoices are received
- Progress is being made or the milestone has been met
- Invoice itemization including percent effort is sufficient and reasonably matches the approved budget