Subrecipient Commitment Form Preparation

Why am I being asked to complete this form?

When Gallaudet is the prime recipient of a sponsored project from an external sponsor and wishes to compensate another organization for its help in carrying out a significant part of the scope of work, it is necessary to establish a subagreement between the organization and Gallaudet. The Subrecipient Commitment Form was designed to collect information about the subrecipient at the proposal stage to verify the information about the subrecipient contained in the proposal and to determine if the other organization’s role is that of a true subrecipient. Collecting this information at the proposal stage allows the process of establishing a subagreement to move forward more quickly at the award stage. The completed and signed Subrecipient Commitment Form must be received before a subagreement will be established. The form will be considered valid if the subrecipient’s authorized representative has signed the form within the past year.


Directions for Completing the Form

The form should be completed by someone who is knowledgeable about your organization’s business processes with input on the scope of work from your organization’s principal investigator (PI). The form also must be approved and signed by your organization’s authorized institutional official.


Section A: Gallaudet Proposal Information. Please complete as much of this information about the Gallaudet project and PI as you can. If you need assistance, please contact the Gallaudet PI/Department.


Section B: Subrecipient Eligibility. The questions in this section are designed to identify subrecipients that will be unable to enter into a subagreement with Gallaudet. If either of the two questions in this section are answered, “Yes,” do not complete the remainder of the form and notify the Gallaudet PI as soon as possible that a subagreement will not be possible at this time.


Section C: Subrecipient Requirements and Responsibilities. Subrecipients and contractors play different roles and have different responsibilities relative to a sponsored project. This section is designed to help your organization determine if it will have a true subrecipient relationship with Gallaudet when carrying out the scope of work this project. This section should be completed after consultation with your organization’s PI to determine if the scope of work is appropriate for a subagreement. If it is not, please notify the Gallaudet PI that a contractor arrangement may be more appropriate.


Section D. Subrecipient Information. This section provides background information on the subrecipient that will be used in preparing the subagreement. It should be completed by an authorized individual who is knowledgeable about the organization as a business entity. This is typically someone in the contracts and grants office.

Subrecipient’s Legal Name: This is the name of the organization that is used for all official purposes. It should not be a nickname. The legal name should be the name of the legal entity authorized to enter into contracts on behalf of the organization not a sub-unit of that organization For example, the legal name of “GM” is “General Motors, Incorporated.” For example, the legal name for Gallaudet is, “Gallaudet University."

DUNS Number: The DUNS number is a nine-digit number, issued by Dun and Bradstreet (D&B), assigned to each business location in the D&B database, having a unique, separate, and distinct operation for the purpose of identifying them.

Organization Address/Performance Site Address: Please include your organization’s legal business address along with the Zip code plus four digits or other postal code if not in the U.S. If the sponsored activity will take place at another location, please provide this address under Performance Site address.

Congressional District (If in the U.S.): Please include the U.S. congressional district of your organization as well as the performance site (where the scope of work will be carried out) if it will be different from that of your organization. To find a specific congressional district, go to http://house.gov/. On the main page, in the upper right hand corner enter the zip code to find out the number of the U.S. congressional district for this area.

Domestic organizations should provide the following:

·         Federal Employer Identification Number (EIN): An Employer Identification Number (EIN) is also known as a Federal Tax Identification Number, and is used to identify a business entity.

·         SAM: The System for Award Management (SAM) is a federal government owned and operated free web site that consolidates the capabilities of the CCR/FedReg, ORCA, and EPLS. SAM collects data from suppliers, validates and stores this data, and disseminates it to various U.S. government acquisition agencies. All federal contractors must register in the SAM database prior to award of any contract or purchase agreement.

·         Cage Code: The Commercial and Government Entity Code, or CAGE Code, is a unique identifier assigned to suppliers to various U.S. government or defense agencies, as well as to U.S. government agencies themselves and also various organizations. CAGE codes provide a standardized method of identifying a given facility at a specific location.

International organizations should provide the following (if applicable.)

·         NAICS: The North American Industry Classification System or NAICS is used by business and the U.S. government to classify business establishments according to type of economic activity (process of production) in Canada, Mexico and the United States.

·         NGAGE Code: CAGE Codes are used internationally as part of the NATO Codification System (NCS), where they are sometimes called NCAGE Codes.

Executive Compensation: Under the Federal Funding and Transparency Act (FFATA), Gallaudet is currently required to collect salary information about each subrecipient’s five most highly compensated senior officials unless (a) this information is already publically available, or (b) the organization received less than 80% of its gross revenue or less than $25M in gross revenue from federal sources during the previous fiscal year.

Subrecipient’s PI: The Gallaudet PI is responsible for the direction and management of the overall project. The subrecipient’s PI is responsible for carrying out a significant part of the scope of work and will be responsible for helping to make programmatic decisions that impact the project as a whole.

Amount of Funding: This is the amount of funds being requested by your organization to support the scope of work included in the proposal. This should include all direct costs and indirect costs (F&A) if applicable.

Cost Sharing: Some sponsors require that the recipients and subrecipients of their funds demonstrate a financial commitment to the project by “sharing” the cost of the project. When an organization pledges such a cost sharing contribution to the project at the proposal stage it often becomes a firm commitment when the award is made. Committed cost share must be tracked and reported to the sponsor. For this reason, cost sharing should not be included in the proposal unless it is required by the sponsor. If your organization is committing cost share to the project please indicate the amount of funds your organization will be contributing to the support of this project.


Section E: Proposal Documents.

Check the boxes next to the documents included in your proposal that are covered under the certifications appearing in Section F. These include:

Statement of Work: This is a description of the scope of work to be performed by the subrecipient. It should be a substantive and important part of the overall project—not just a supplementary service. This must be submitted as part of the Gallaudet proposal.

Budget and Narrative Budget Justification: This refers to the costs associated with carrying out the subrecipient’s scope of work. The budget provides the financial information, and the budget justification provides an explanation of how these costs were determined.

Biosketches: A “Biosketch” provides information on the background and experience of any person considered to be among the “key personnel” on the project. Key personnel are those individuals who will be responsible for carrying out the scope of work and have decision-making roles. This does not include consultants/ independent contractors and typically does not include students. Some agencies have a specific format that must be used to prepare a biosketch. Consult with the Gallaudet PI if you have questions about this component.

Small/Small Disadvantaged Business Subcontracting Plan: This is required under federal contracts only. In such cases subrecipients are referred to as a “subcontractors.” A subcontractor may be required to provide such a plan at the proposal stage if (a) the amount of the subcontract is anticipated to be above $650,000 and (b) such a plan is required by the prime sponsor at the proposal stage. Consult with the Gallaudet PI to determine if this requirement applies to this proposed project.

Major Project Status: The “Major project” designation applies only to federal projects. A major project is defined as a project that requires an extensive amount of administrative or clerical support, which is significantly greater than the administrative services included as part of an organization’s indirect cost (F&A) rate. This designation must be carefully justified in the subrecipient’s budget justification.

Other Support: “Other support” refers to other external funding (grants, cooperative agreements contracts) currently supporting any of the key personnel. Some sponsors require a description of both “current” and “pending” support at the proposal stage. Consult with the Gallaudet PI to find out what is required by the sponsor.


Section F: Certifications.

1. Facility and Administration (F&A) Rate: This is the percentage of the project’s direct costs that an organization may charge the sponsor for the “indirect” costs associated with housing and managing a sponsored project. Such costs include utilities costs and administrative time and effort to support the project. These costs also are sometimes referred to as “overhead.”

·         A “federally negotiated F&A rate:” This means that an agency of the U.S. federal government has reviewed the organization’s indirect cost proposal and has agreed in writing that the organization may charge the U.S. federal government a certain percentage of direct project costs for F&A (indirect) costs. If your organization has an F&A rate approved by a U.S. federal agency, please attach a copy of your F&A agreement to the Subrecipient Commitment form or provide a webpage link to this information.

·         Other Rates: If your organization does not have a U.S. federally negotiated F&A rate, and plans to charge for indirect costs, please attach an explanation as to how this rate was derived.

Please note: International organizations typically do not receive reimbursement for F&A costs from the U.S. federal government unless the foreign organization has negotiated an F&A rate agreement with a U.S. federal agency. A U.S. federal sponsor also may have a policy of paying a specific F&A rate to foreign and international organizations.

·         Not applicable: Check this box if your organization is not requesting F&A costs.

2. Fringe Benefit Rates: Fringe benefit rates include the percentage of salary and/or the amount your organization pays for employee retirement, health insurance, Medicare, and Social Security, etc. It represents the employer’s contribution to these costs—not the employee’s contribution.

·         Composite/Other Rates: Some organizations negotiate their fringe benefit rates with the U.S. federal government just as they do their F&A rate. Other organizations use actual rates for each employee. Still others use composite rates for different classes of employees.

For this section, indicate how the fringe benefit rates were calculated. Attach a copy of the fringe benefit information to the form or provide a link to this information on your organization’s webpage.

3. Research Subject Compliance Information:

·         Human Subjects: If your organization will be carrying out human subjects’ research under the subagreement with Gallaudet mark, “Yes,” on the form. Please provide your organization’s Office of Human Research Protection (OHRP) approved Federal Wide Assurance (FWA) number. If your organization does not have an FWA #, attach an explanation as to how your organization will comply with U.S. federal regulations and policies for the protection of human subjects.

·         Animal Subjects: If your organization will be carrying out animal research under the subagreement with Gallaudet mark, “Yes,” on the form.

4. RCR (for NSF-funded projects only): The National Science Foundation (NSF) requires all domestic and international subrecipients to have a plan for meeting Responsible Conduct of Research (RCR) requirements. This plan should describe how education and training in the Responsible Conduct of Research (RCR) will be provided to all students (undergraduate and graduate) and postdoctoral scholars who will be supported by NSF funds. RCR training is required under the America COMPETES (America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science) Act. While training plans are not required to be included in the subrecipient’s portion of the proposal submitted to NSF, subrecipients are advised that all such plans are subject to review by Gallaudet and NSF upon request.

5. Lobbying (federal funding only): Federal sponsors require grantees to include the lobbying certification in agreements, contracts, and subcontracts exceeding $100,000. Signed certifications regarding lobbying must be obtained by the Gallaudet from subrecipients and contractors. The lobbying certification informs the sponsor if Gallaudet or any of its subrecipients have paid a lobbying entity to influence an officer or employee of a U.S. federal agency, a member of the U.S. Congress, or an officer or employee of the U.S. Congress, or an employee of a member of the U.S. Congress relative to the award of this grant/contract.

6. Conflict of Interest: Complete this section only if the proposal is being submitted to any of the following sponsors:

·         Public Health Service/National Institutes of Health

·         National Science Foundation

·         Subcontracts from PHS/NIH or NSF

7. Additional Debarment and Suspension Information: People and organizations may be debarred from receiving U.S. federal financial and non-financial assistance. Debarment or suspension of a participant in a program by one agency has a U.S. government wide effect. Please attach an explanation for any “Yes” answer. While a “Yes” answer to any of these questions will not automatically exclude your organization from participating in this proposed project, it will require the Gallaudet conduct a risk assessment before making a decision to enter into an subagreement with your organization.

8. Audit Status/Fiscal Responsibility: Any non-profit entity that has expended at least $750,000 in U.S. federal funds within the organization’s previous fiscal year is subject to the Circular A-133/UNIFORM GUIDANCE single audit requirement with the exception of foreign organizations. For-profit organizations and U.S. federal government agencies also are not subject to A-133/UNIFORM GUIDANCE audit requirements.

·         Agencies subject to A-133/UNIFORM GUIDANCE requirements should attach a description of any findings or exceptions noted in their most recently completed A-133/UNIFORM GUIDANCE audit. An update of this information may be requested prior to establishing a subagreement with your organization.

·         Organizations not subject to A-133/UNIFORM GUIDANCE audit requirements will be required to confirm that the organization still is not subject to A-133/UNIFORM GUIDANCE audit requirements and fill out the a mini-audit questionnaire prior to the establishment of a subagreement.

Please note: When applying for funds from agencies under the U.S. Department of Health and Human Services foreign organizations and for-profits that have expended a total of $750,000 or more under one or more awards from the U.S. Department of Health and Human Services (as a direct grantee and/or under a consortium participant) will be required to have a financial-related audit of all HHS awards as defined in, and in accordance with, the Government Auditing Standards or an audit that meets the requirements of OMB Circular A-133/UNIFORM GUIDANCE.

9. For-profit Organizations (only):  Check the category that applies:

·         “Small Business” is organized for profit; has a place of business in the United States; makes a significant contribution to the U.S. economy through payment of taxes or use of American products, materials or labor; is independently owned and operated; is not dominant in its field, on a national basis; and is no larger than SBA’s small business size standard for its industry. A business can find the size standard for its industry by consulting the Small Business Administration’s Table of Size Standards.

·         “Small Disadvantaged Business” as used in this provision means a small business that: (i) has received certification as a small disadvantaged business consistent with 13 CFR part 124, Subpart B; (ii) no material change in disadvantaged ownership and control has occurred since its certification; (iii) where the is owned by one or more individuals, the net worth of each individual upon whom the certification is based does not exceed $750,000, after taking into account the applicable exclusions set forth at 13 CFR 124.104(c)(2); and (iv) is identified, on the date of its representation, as a certified small disadvantaged business in PRO-Net, the database maintained by the Small Business Administration.

·         “Woman-Owned Small Business” as used in this provision means small business that: (i) is at least 51% unconditionally owned by one or more women; or in the case of any publicly owned business, at least 51% of the stock of which is unconditionally owned by one or more women; and (ii) whose management and daily business operations are controlled by one or more women.

·         “Veteran-Owned Small Business” is a small business that: (i) is at least 51% unconditionally owned by one or more veterans (as defined at 38 U.S.C. 101(2)); or in the case of any publicly owned business, at least 51% of the stock of which is unconditionally owned by one or more veterans; and (ii) whose management and daily business operations are controlled by one or more veterans.

·         “Service-Disabled Veteran-Owned Small Business” as used in this provision means a small business that: (i) is at least 51% unconditionally owned by one or more service-disabled veterans (as defined at 38 U.S.C. 101(2), with a disability that is service connected, as defined in 38 U.S.C. 101(16)); or in the case of any publicly owned business, at least 51% of the stock of which is unconditionally owned by one or more service-disabled veterans; and (ii) whose management and daily business operations are controlled by one or more service-disabled veterans or, in the case of a veteran with permanent and severe disability, the spouse or permanent caregiver of such veteran.

·         “HUBZone Small Business” as used in this provision means a small business that appears on the list of Qualified HUBZone Small Business maintained by the US Small Business Administration.


Section G: Authorized Representative Approval. Only an authorized official of the subrecipient should sign this form. The official’s signature indicates that he/she is authorized to provide this information and that he/she is prepared to commit the organization to the proposed project and abide by the policies of the sponsor if the project is funded.