Office of Research and Project Administration

Subaward Policy
(Effective May 1, 2009)

The proper classification of a transaction as a subaward or other procurement action at the time it is proposed is critical to ensure proper accounting for costs and compliance requirements. Misclassification may result in delays in subaward processing or inaccurate calculation of costs (e.g., failure to include or exclude Facilities and Administrative, or F&A, costs) and may result in the Principal Investigator (PI) having insufficient funding to carry out the proposed program. In rare cases, incorrect classification of costs may jeopardize the ability of the program of work to proceed (e.g., if a Subrecipient was determined not to have the internal controls necessary to receive funding from Princeton.)  Please note: F&A waivers or reductions are not granted to remedy incorrect classifications of costs. PIs may request supplemental funding from sponsors, but such requests are rarely granted.

Princeton follows the requirements found in OMB Circular A-133, Section B.210 to distinguish subawards from other procurement actions, as follows:

Princeton will issue a subaward when:

• Princeton (with assistance from its sponsor, as required) determines who is eligible to receive the subaward;
• The Subrecipient has its performance measured against whether the objectives of the sponsored program are met;
• The Subrecipient has responsibility for programmatic decision-making and when the nature of the subrecipient's statement of work could result in intellectual property or publishable results being developed by the subrecipient;
• The Subrecipient assumes responsibility for adherence to applicable sponsor program compliance requirements (e.g., approval to use human subjects or animal subjects); and
• The Subrecipient uses sponsor funds to carry out a program (Statement of Work) of Princeton as compared to providing goods or services.

Princeton will use other procurement actions when the vendor:

• Provides the goods and services within its normal business operations;
• Provides similar goods or services to many different purchasers;
• Operates in a competitive environment;
• Provides goods or services that are ancillary to the operation of Princeton's sponsored project;
• Is not subject to compliance requirements of Princeton's sponsor.