Collaboration Guide:
When JMU is the Lead Institution

Subrecipient or Contractor?

External entities and individuals that will perform work on a sponsored project must be classified as either a subrecipient or a contractor.  It is important to make this determination correctly at the proposal stage, as it affects the legal relationship JMU will have with the entity, as well as the indirect cost calculation and budget classification.

This determination is made on a case-by-case basis based on the characteristics of the entity.  Not all characteristics need to be or will be present to determine whether the entity/individual is a subrecipient or contractor.  An entity's classification may change from one project to the next, depending on the scope of work involved.

Making the Determination

For each external entity in a proposal, the Principal Investigator (PI) must complete the Subrecipient or Contractor Checklist and email it to the Office of Sponsored Programs (OSP).

Using the completed checklist, OSP will make a final determination on whether the work will be performed under a subaward or under a procurement contract.

  • If the entity/individual is a contractor - please budget accordingly and plan to work with Procurement Services.
  • If the entity/individual is a subrecipient -
    • Please provide collaborator contact information to OSP, so we may assist in coordinating required subrecipient materials prior to proposal submission.
    • If awarded, JMU’s PI will be responsible for monitoring the activities of the subrecipient affecting the project.  The subrecipient should submit progress reports, technical reports and other deliverables to the PI by specified due dates. The PI is responsible for forwarding copies of the subrecipient’s progress report and/or technical report(s) to the prime awardee if required and providing a copy to OSP for file copies.
    • The PI is also responsible for reviewing and approving invoices from subrecipient for adherence to the budget and reasonableness to the work accomplished as noted by the technical reports. The signature of the PI on the invoice indicates that the review has taken place and that the invoice adheres to budget.  Records relating to each subrecipient must be retained for up to 5 years after the project closeout unless the sponsor requires a longer period.

 Checklist for Subrecipients

The list below is what may be needed from collaborators before proposal submission when JMU is the lead institution. Always check the specific guidelines and contact OSP if uncertain.  Samples and templates may be available on the Forms, Tools and Resources page.

Item Subrecipient
1. Completed Subrecipient Commitment Form: Must be signed by an Authorized Official (an individual who has been delegated the legal authority to commit the organization to a binding agreement and other organizational commitments). Required
2. Statement of Work (SOW): This is a stand-alone project description of your entity's effort (including objectives, tasks, and deliverables) on the collaborative proposal.  The SOW will be used as the basis for your subaward agreement should the proposal be selected for funding by the sponsor, so clearly describe your role and responsiblities on the project. Required
3. Line-item Budget: Standard sponsor budget forms should be used.  If the sponsor does not specify a budget form, you may use your internal budget templates as long as the project costs are separated by funding period or year. Required
4. Budget Narrative/Justification: A written narrative that corresponds with the line-item budget. Required

Subrecipient Contacts:  Please complete the Federal Demonstration Partnership FDP Attachment 3B forms Page 1 (required); Page 2 (If applicable).  These forms are available at the following URL:

6. Fringe Benefit and Facilities and Administrative (F&A) Rate Agreement: If charging fringe benefits and/or indirect costs, a copy or webpage of the substantiating rates must be provided. If the subrecipient does not have their own federally negotiated indirect cost rate agreement (NICRA), per the Office of Management and Budget (OMB) “2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards”  the subrecipient may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC). Costs must be consistently charged as either indirect or direct costs, but may not be double charged or inconsistently charged as both. If 10% indirect rate is chosen, this methodology once elected must be used consistently for all Federal awards until such time as a non-Federal entity chooses to negotiate for a rate, which the non-Federal entity may apply to do at any time. If applicable
7. Biographical Sketch or Curriculum Vitae for all Senior/Key Personnel: If required, in sponsoring agency-required format. If applicable
8. Current and Pending Support for all Senior/Key Personnel: If required, in sponsoring agency-required format. If applicable

Facilities, Equipment, and Other Resources: If required, a description of facilities, equipment, and other resources already available that your entity is providing for this proposal.

If applicable (check with JMU principal
10. External Collaborator Certification: In accordance with James Madison University's Policy 2203, Financial Conflict of Interests Disclosure for Sponsored Programs, all subrecipients responsible or partially responsible for the design, conduct, or reporting of the project must complete and sign the External Collaborator Certification. Required if federal funded
research proposal, EPA, or PHS funded proposal
11. Letter of Commitment: Must be on letterhead and signed by an Authorized Official (AO). This letter should include any monetary value of the total cost sharing/matching, if any, and state plans to participate and accept a subaward agreement from James Madison University in accordance with the approved statement of work and project budget and abide by all of the associated terms and conditions if the proposal is funded. If applicable

Additional requirements may apply should your project include human or animal subjects.

The above items should be approved by the respective institutions/organizations and then forwarded seven (7) business days before the sponsor deadline to the Office of Sponsored Programs by email at or in hardcopy to the following address:

U. S. Postal Service Express Delivery

Ms. Tamara Hatch
Interim Director, Sponsored Programs
James Madison University
Office of Sponsored Programs, MSC 5728
800 South Main Street
Harrisonburg, Virginia 22807-0001

Ms. Tamara Hatch
Interim Director, Sponsored Programs
James Madison University
Office of Sponsored Programs
1031 Harrison Street, JMAC 6, Suite 26
Harrisonburg, Virginia 22807-1034

Back to Top