Justification Nation Part 4: Justifying Subcontractors and Consultants – Starting Off on the Right Foot

mapEstablishing subcontracts during the application phase can appear quite complicated and time consuming. At a time when we’re rushing around to complete the application with the investigator, we have to work with another university and ANOTHER investigator that we have never met, and ask them for information, often without ever seeing them face to face, and they have to produce this information really quickly. The subcontract information has to be institutionally endorsed at the home university before it is submitted in the application, which takes time, and that’s essential for the application to be approved at the prime institution before our investigator submits to the agency. The coordination necessary to achieve this is impressive. (Now imagine an application for an application with a number sites – subcontracts – and the planning involved!)

While subcontracts can take time to coordinate, they are not as complicated as they seem. Subs are the backbone of research and can be easily managed once you’ve done them a few times and are familiar with the process. It helps to think of a subcontract like a mini-grant application. Consultant and vendor agreements are more streamlined.

So how is it done, and what are the keys to success when justifying a subcontractor on your budget? What about a consultant? How do you determine the difference between a subcontractor, consultant and a vendor in the first place? In the era of collaborative research, subcontracts and consultants are a part of research collaborations on a regular basis – what are the best practices for documenting these relationships on budget justifications? Let’s look at justifying subcontractors and consultants on grant applications.

A-133 Audit Criteria

The criteria for the A-133 audit, and the IRS both help guide our determination for classifying the type of work that subcontractors, consultants and vendors perform (consultants and vendors are generally considered a similar category).

Subcontractors

  • Provides substantive programmatic work or analysis
  • Responsible for scientific aims and decision making on the program which has measurable performance objectives
  • Subject to Federal compliance standards
  • Retains rights, relationship to study participants, etc.
  • Provides cost sharing on project
  • Can receive flow down of original terms of prime contract

Consultants/Vendors

  • Provide goods and services as a part of their normal business operations to many purchasers
  • Operate their business in a competitive environment
  • Provide their specified service to the research program to support the outcome; do not direct or contribute guidance to the research aims.
  • Ancillary to the operation of the Federal program (another service could replace them).
  • Is not subject to the compliance of the Federal program.

TIP: When a “consultant” with academic expertise has a role on the grant that is consistent with their academic appointment and they are using their institutional resources to achieve the work on the grant, they should be proposed as a SUBCONTRACTOR.

BEST PRACTICES FOR ESTABLISHING SUBCONTRACTORS ON PROPOSALS

  1. Plan your proposal process in advance, ask for every item you need up front, and give a deadline.
  2. Communicate with your subcontractors by phone (have your PI pave the way with research administrators at the site/s).
  3. Don’t assume that the sites assemble subcontracts the same way that your institution does – on the contrary! Provide detailed directions to the sites, and follow up. Be accessible and answer questions in a timely manner.
  4. Provide draft letters, materials (budget justifications, budgets, etc) to speed the process along.
  5. Build a great relationship and be very helpful. This will not be the last time you will work with this site – your PI will be working with this site for his or her career.

BEST PRACTICES FOR ESTABLISHING CONSULTANTS

  1. Start off with a conversation with your PI – what will the consultant do on the project?
  2. Talk to the consultant and introduce yourself, offer to draft a letter for the consultant to review after getting some key pieces of information: hourly rate, length of time the consultant will work on project, scope of work, and whether or not the consultant will be traveling.
  3. It’s preferable to provide a draft letter for the consultant because in most cases, unless a consultant has done a lot of work on sponsored projects, information tends to get left out.
  4. Your institution’s office of sponsored research may have template language for you to use in the consultant letter – check first before sending.

BUILDING YOUR BUDGET JUSTIFICATION

The subcontract budget justifications are inserted after the prime budget justification information in the application. (F&A is taken on the first $25,000 in direct costs.)

Consultants are budgeted in the other costs section of your budget, and their work is justified in the other cost section of the prime budget justification. Their letters are inserted as supporting documents to the application.

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