Understanding & Amending a Subaward
A subaward is an agreement with a third party (usually an organization, although it can be an individual) to perform substantive programmatic work or conduct a significant portion of the project. The work to be performed is integral to the overall success of the sponsored project and is carried out in compliance with prime award guidelines. A subaward generally involves greater performance expectations, including formal milestones and deliverables, than an Independent Contractor Agreement (ICA). The individual primarily responsible for accomplishing the work promised under a subaward may often be considered, or even given the title of, a co-Principal Investigator (co-PI) with the CUNY PI. A co-PI often expects to be able to publish the results of their research.
An ICA is the document by which RFCUNY retains the services of an independent contractor on behalf of a CUNY PI. An independent contractor (which can be an individual or a company or other organization) performs a discrete task that assists a PI in accomplishing the work the PI has agreed to perform for the award sponsor. Independent contractors are in business for themselves and control when, how, and where services are performed, towards a promised deliverable as a goal. An individual is an independent contractor if the payer has the right to control or direct only the result of the work and not what will be done or how it will be done. RFCUNY refers to an ICA for less than $5,000 as a Memorandum of Understanding (MOU). The governing principles are fundamentally the same.
No. Each of these items is an obligation of the college. RFCUNY is a fiscal administrator for CUNY and its components. It is the college’s responsibility to comply with sponsor requirements, University policy, and applicable governmental laws and regulations. The college is also responsible for seeing that the principal investigator carries out a sponsored project in compliance with the terms of the award, University policy, and city and state requirements.
With regard to the protection of human and non-human subjects in CUNY research (IRB and IACUC approvals), CUNY has specifically agreed with RFCUNY that CUNY has responsibility for compliance with applicable laws, regulations and policies in sponsored programs administered by RFCUNY.