Collaboration is generally a good thing, and Bates has a stewardship responsibility to the federal government and other sources of grant support to ensure that collaborative grant funds are used reasonably and appropriately.

If your project includes subawards to partnering institutions, our responsibility includes monitoring the grant fund use and achievement of grant project objectives. Bates employs a risk-based approach to subrecipient monitoring, and we focus more frequently and robustly on subrecipients who pose an elevated risk for non-compliance. It is Bates’s practice to request relevant information from the subrecipient and conduct the subrecipient risk assessment prior to proposal submission.

Please note that a subrecipient refers to an entity that receives a subaward to carry out part of a sponsored project. It differs from a contractor that provides commercially available property or services necessary for the project’s success.

Outgoing subawards can be structured with either a cost-reimbursable or fixed amount payment method, depending on the determination of appropriateness.

Cost-reimbursable subawards require Subrecipients to invoice Bates College for actual expenses incurred in the course of their performance of the statement of work, and Bates College then reimburses those costs once approved. Bates College uses cost-reimbursable subawards for projects involving theoretical or intangible deliverables.

Fixed amount subawards are based on meeting various milestones and/or deliverables, each of which has a predetermined associated cost. Bates College requires certification in writing that the milestone and/or deliverable was completed prior to providing payments. A fixed amount subaward must meet the requirements outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.201). Furthermore, per 2 CFR 200.332, prior written approval from a Federal sponsor is required to issue a fixed price subaward on a federal award. Bates College adheres to the federal regulations and follows the Federal Demonstration Partnership guidances and practices for the management of federal subawards.

If you are uncertain whether an entity should be considered a subrecipient or a contractor or what funding mechanism is right for your collaboration, please be in touch with the Office of Sponsored Programs.