A subaward or subcontract can be distinguished from a service or consultant by the nature of the work they will perform. An organization is considered a subaward when it:

• Makes substantial contributions to the project that may not be reduced to a set price per unit;
• Has its performance measured against whether the objectives of the project are met; and
• Has responsibility for programmatic decision making.

UAF requires specific documentation to certify commitment of each subrecipient. Remember, the university claims F&A recovery on only the first $25,000 of each subaward, even if the project spans multiple years.

Each UAF subrecipient organization is required to provide OSP with a Subrecipient Commitment Form (Form OSP-007). This form should be completed and signed by the Authorized Organization Representative (AOR) and the PI for the subrecipient. Along with this form, the subrecipient is required to include at a minimum:

1. A statement of work to be performed by the subrecipient organization/PI in the proposed project;
2. An itemized budget and justification for the work to be performed by the subrecipient;
3. Other documents as needed (i.e. CVs, C&Ps, copies of F&A or benefits agreements, copies of IRB or IACUC protocols, etc.)

UAF PIs who plan to be subrecipients on other institutions' projects, should check with the prime institution to determine what documentation to provide. At the minimum, OSP requires a statement of work, budget, and budget justification.

For further information regarding subrecipients, see The Office of Grants and Contracts Administration's subaward section manual.

Note regarding "Sub-subrecipients": Unless substantial justification can be made, a subrecipient should generally not request any further subawarding of their portion of work. Instead, the prime awardee should budget all subawards/subcontracts so that they fall under the prime's authority.

Treatment of Cross-MAU/Cross-Department Activities in Sponsored Programs

If one MAU (the prime) writes a proposal which includes activity that will be conducted by one or more of the other UA MAUs (for example, UAA submits a proposal which includes work that will be completed UAF), the work completed by UAA, UAF, and UAS IS NOT treated as a subrecipient. UA is one institution so no subaward or subcontract arrangement can exist even when activities cross MAUs or departments within an MAU. All costs incurred should be included in the prime MAU's proposal budget. It is helpful for the various activities to be clearly identified with each specific MAU. For proposal submissions to the National Science Foundation, a collaboration between MAUs is appropriate unless prohibited by the program competition.

In general, the F&A cost rate for the primary MAU should be used for the whole proposal unless the activity at other locations is material. However, the funding agency may require multiple rates for the proposed project regardless of materiality to the project. Agency guidelines and requirements are the primary consideration in deciding if it is appropriate to use multiple rates. In addition, if the activity at the primary campus is 90% or more of the total project then the activity at other locations is probably not material to the project and doesn't warrant the use of multiple rates. Contact UA Cost Analysis for more information.

Note: NSF requires subawardee budgets & justifications be entered in FastLane's budget section and not in the Special Information and Supplementary Documentation section!

Materials and supplies are project-specific, expendable, and cost less than $5,000 per item. Budgets should clearly itemize supply lists when they are over $1,000. Be sure to differentiate between expendable supplies used in the lab and office and supplies used in the field.

Supplies should always be referred to as "project supplies" in the budget and justification. Since office supplies are not easily identifiable for a specific project and perceived for common use, they are normally an indirect cost.

Services

When preparing the budget, include all expenses to be incurred for services during the project period, such as: media services, computer services, lab analyses, consulting, animal care, boat and air charters, and UAF Recharge Center fees. Services also include both oral and written communication costs related to the project such as toll charges, fax, postage, and publication costs. When describing consultant costs in the budget justification, mention any consulting fees and address why the individual is required for the task.

Service or Subaward?

A service can be distinguished from a subaward by the nature of the work the service provider will perform. An organization is considered a vendor service when it:

• Provides similar goods and services to different clients within normal business operations;
• Operates in a competitive environment; and
• Provides goods and services ancillary to the operation of the program at a set price per unit

UAF Recharge Center Fees

Recharge center rates are treated as a direct cost and cannot be included as an MTDC exclusion. The rates are not "fully loaded' and do not include building depreciation, administration costs, etc., which are then recovered through F&A. The recharge rates are "actual ulitilization" rates, which only cover the actual costs for the recharge services such as labor, materials and supplies, depreciation on equipment, etc. If you have other questions about how the recharge rates are developed, please contact SW Cost Analysis).

UA Employees

Current UA employees CANNOT be paid as consultants on UAF proposals. However, emeritus faculty can be paid as consultants on UAF proposals only if:

1. They have not been paid as a UA employee in the past 12 months;
2. They are not doing a service that would fall under the normal scope of work of any UA employee;
3. They are not using university resources such as office space, equipment, labs, etc. to perform the service(s);
4. They are not being supervised on a day-to-day basis; and
5. They are given a set task to complete with an expected deliverable.

All items deemed services will have full F&A charged against them, unless it can be demonstrated that the vendor can be treated as a subaward under the following policy:

Treating Vendor Services as Subawards

"If a department believes that it has a contract for allowable goods and services that should not recover F&A costs on the excess over $25,000, that department must be able to clearly demonstrate that the contract does not require the same level of F&A support as other contracts for goods and services. To qualify for the exclusion, the vendor contract must meet the following criteria:

• The contract must be in excess of $50,000.
• Normally, the primary administrative costs associated with the contract are only the initial costs incurred in the bidding process.
• Limited additional administrative costs will be incurred as a result of the short-term of the contract, few types of goods and/or services purchased, quantity of goods purchased is small, or the vendor will receive a small number of payments.

The unit should follow the same process used by their respective MAU for F&A waivers by providing a written request explaining the need and justification for exceptional treatment to their respective campus’s Chief Financial Officer or authorized designee for review and approval. MAUs that currently charge a penalty to departments for waivers have the option of treating these situations as exceptions to those penalties."

OSP Procedures

If a PI or department wants to treat a vendor as a subaward, fill out the Request for Waiver to Treat Vendor Service Contract as Subaward form. Notice of intent to seek a waiver should be given to OSP as far in advance as possible. There are no guarantees that a waiver will be granted and it could require the budget to be changed, so lead time is key with these request. This form will be required for such requests and should be included with the proposal package to OSP. The memo is an internal UAF document only for review and approval of a waiver.

You must request tuition for a student researcher unless the sponsor will not pay tuition costs (include documentation w/proposal). If you wish to supply tuition from another source, include a memo confirming the source and available funds with the proposal.

Please note that students must be in the state for 2 years to qualify for the in-state tuition rate, or they can apply for resident status after residing in the state for one year under the university's "bona fide resident" provision. Students having non-immigrant visa status are not eligible for Alaska residency.

For budget planning on proposals, the OSP recommends 2 years of out-of-state tuition. Full time graduate students are enrolled in 9 credits each semester (18 credits for academic year).

• Graduate Fall 2009 resident tuition is $338 per credit 
• Graduate Fall 2009 non-resident tuition is $691 per credit 
• No more than 18 credits can be taken for undergraduate students and no more than 14 credits for graduate students; per UAF policy http://www.uaf.edu/catalog/current/academics/regs1.html

Here are some examples of Other Direct Costs. This list is not all-inclusive.

• Air/Vessel Charters - see Services and Consultants

• Animal Care Costs

• Consultants - see Services and Consultants

• Graduate Student Tuition - see Tuition

• Page charges/publication costs

• Participant Support Costs - This is an NSF-specific cost category, defined by NSF as "...costs of transportation, per diem, stipends and other related costs for participants or trainees (but not employees) in connection with NSF-sponsored conferences, meetings, symposia, training activities and workshops. (See Chapter II, Section D.7) Generally, indirect costs (F&A) are not allowed on participant support costs. The number of participants to be supported must be entered in the parentheses on the proposal budget. These costs also must be justified in the budget justification section of the proposal. Some programs, such as Research Experiences for Undergraduates, have special instructions for treatment of participant support." Note: Because this is a sponsor-specific exclusion from the MTDC base when charging F&A and not applicable to all sponsors, F&A should be charged on similar costs to all other sponsors unless explicity prohibited by sponsor or program guidelines.

• Sample analysis - see Services and Consultants

• Shipping of equipment/supplies to field locations

• Toll/Communication charges

• UAF Recharge Center costs