Considerations in Issuing International Subawards
What makes an international subaward different from a U.S. domestic subaward? What must organizations take into account before moving forward with an international subsite? Let’s review common questions and considerations to explore when issuing an international subaward.
As many of the U.S. funding agencies push for global collaborative research, Research Administrators are bearing the burden of ensuring compliance with the plethora of rules and regulations which are required of projects with international subawards. The National Institutes of Health recently issued NOT-OD-23-182, which mandates that foreign subrecipients provide access to copies of all lab notebooks, data, and research outcomes documentation to the pass-through entity at least once per year. Many institutions are having to implement new processes and procedures for oversight of international subsites that are not typically in place for domestic subawards. In addition to the standard terms and conditions which must flow to subsites, there are additional considerations which must be taken into account when preparing and issuing subawards to international entities.
- Does the site have a representative who speaks and writes in English? Ideally, if your Research Administration office can negotiate and speak directly with a site representative, it will allow for more transparency between the parties as well as reduced language barriers.
- If the site does not have a representative that speaks English, do translation services need to be included in the budget? Oftentimes Principal Investigators may want to translate if they can, but it is a better practice to have a third-party translator involved. By including the translation service cost in the proposal budget, you can ensure that costs are pre-approved by your sponsor or funding agency. Having to request a re-budget after an award is made can delay project initiation, as well as result in reduced funds available for other activities should the overall award amount not be increased.
- Would the site be able to pass an export control review by your institution? As many institutions can attest, providing data and/or materials to international countries can involve navigating the burdensome and ever-changing export control regulations. It is imperative to resolve export control questions before an award is made to your institution or sub-awards are initiated after receipt of the prime award.
- Does the site have a comparable ethics review board in place? Human subjects studies, much like export control, are governed by a vast amount of regulations and oversight. Ensuring that your subsite already has an ethics review board, comparing to U.S. domestic IRB panels, will allow for faster review and approvals of your international subsites.
- Does the site accept that all transactions (invoicing, payment, etc.) will be done in U.S. dollars? And how will payments be issued? It is far easier for a domestic institution to issue payment in U.S. dollars to a subsite than to issue payment in a foreign currency. Additionally, not all international sites can accept hard checks or wire payments to bank accounts. Some subsites may require physical currency as payment; for example, some remote locations may require physical currency for patient incentive payments in order to entice more potential subjects to enroll.
- Which governing law prevails? Many higher educational institutions which are state-affiliated are required by law to accept only that state’s laws in their agreements. When dealing with international organizations or subsites, is there wiggle room to accept another state’s laws, such as New York or Delaware?
This article only touches on a few points that must be considered when drafting and issuing subawards to international subsites. It behooves your organization to create terms sheets or draft questionnaires to be completed at proposal stage in order to prevent delays in issuing the subaward. The more information you have before you begin the subaward process, the faster and easier it can be to execute that subaward.
Special Acknowledgement must be given to the Grants and Contracts Officers of the Abigail Wexner Research Institute in Columbus, Ohio, particularly to Andrew Loreno, without whom this article would be sorely lacking in information.
Authored by Meaghan Ventura, Lead Sponsored Projects Officer
Abigail Wexner Research Institute at Nationwide Children’s Hospital
SRAI Catalyst Committee
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