International Subrecipients

• Follow  SPA's standard procedure for issuing subawards to non-U.S. organizations.
• Ensure the subrecipient’s scope of work clearly defines their responsibilities and expected deliverables.

• All international subrecipients must obtain a UEI from SAM.gov.
• When the prime sponsor is federal, the subrecipient’s UEI is required for reporting purposes.

• SPA will forward proposed subawards to the export officer.
• The export officer reviews the scope of work and subrecipient to determine if a license or other U.S. government authorization is required before proceeding.
• For more export guidance, see Research Compliance → Export Compliance.

• Permits or licenses may be required for international shipment of biological or clinical samples, in addition to a material transfer agreement (MTA).
• Contact  Environmental Health and Safety for guidance.

• If the international subrecipient’s scope involves human subjects, coordinate with the Human Research Protections Office (HRPO).
• If animal research is involved, coordinate with the Office of Animal Welfare Assurance (OAWA).
• For Animals and human subjects compliance, see Research Compliance → Human Subjects/Animal Research.

Ensure the subaward clearly describes:

• Clear scope of work. The subrecipient’s scope of work should clearly define their responsibilities. Confirm that collaborators understand expectations, their roles, obligations, and any sponsor or project requirements, including milestones and deadlines.

• Inclusion of award terms. Certain award terms and regulations must be passed to all subrecipients, domestic or foreign. SPA will determine which terms apply to foreign collaborators, who may need assistance interpreting sponsor policies.

• Payment issues. SPA usually issues subawards to foreign subrecipients on standard cost-reimbursement terms. If concerns arise about performance or fund management, payments may be tied to milestones. PIs can propose milestone schedules; fixed payments are issued when milestones are met. Federal approval is generally required for fixed-price subawards.

• Cash advances. Some foreign subrecipients may need cash advances to begin work. SPA will review requests and establish appropriate payment clauses; sponsor approval may be required.

• Invoices are received from the subrecipient.
• Progress is being made and the milestones are met.
• Invoice itemization including percent effort is sufficient and reasonably matches the approved budget.
• UMB's PI reviews and approves in writing all expenditures for work completed during the period stated on any invoice received.