Federal Subcontracts

Procedures

The first step would be to determine whether Vanderbilt is the prime recipient or the subrecipient of the federal funds.  See below.

Incoming Federal Subcontracts

(When the other party is the prime recipient and subcontracting to VUMC)

Submit a complete package to GCM. In addition, please also send the following information as well:

  1. Name of other party/sponsoring agency or person(s).
  2. Description of services to be provided under the contract, and pertinent history behind the services (including but not limited to hazards of any substances to be investigated).
  3. Name, title, and phone number of contact person/sponsoring agency at other party.
  4. Name and department(s) of principal investigator, faculty person, or staff person or person responsible for services to be provided under the contract.

If you’ve already submitted Vanderbilt’s portion of the grant application through GCM, then the Contracts Analyst or AAII will pull a copy of the following documents from the grants file. If by chance these documents have not been sent then the following will also need to be completed and routed so that GCM may update COEUS.

  1. Transmittal Form
  2. Letter of Intent
  3. Conflict of Interest
  4. IACUC approval (if applicable)
  5. Protocol (if applicable)
  6. Please note that we will be able to verify the Certificate of Human Subjects Training (only applicable if IRB required) and IRB approval (if applicable) through Lotus Notes.

Outgoing Federal Dollars

(When VUMC is the prime recipient of federal funds)

Submit a complete package to GCM. In addition, please also send the following information as well:

  1. Name of other party/sponsoring agency
  2. Letter of Intent
  3. Scope of Work -- Description of services to be provided under the contract, and pertinent history behind the services (including but not limited to hazards of any substances to be investigated).
  4. Name, title, and phone number of contact person/sponsoring agency at other party.
  5. Notice of Grant Award
  6. Protocol (if applicable)

At this point of the process the grant application will be in the grants file, therefore the Contracts Analyst or AAII will be able to pull a copy of the following documents from the grants file in order to start drafting a subcontract.

  1. Transmittal Form
  2. Conflict of Interest
  3. Informed Consent
  4. Other Party’s budget
  5. Other party’s IRB approval (if applicable)
  6. Other party’s IACUC approval (if applicable)
  7. Other party’s Certificate of Human Subjects Training (only applicable if IRB required)

Required Terms for Incoming Federal Dollars

(When the other party is the prime recipient and subcontracting to VUMC)

These are some of the terms required in a Incoming Federal Subcontract. The other party will draft the subcontract as they are the prime recipient of the federal funds. Some of the required terms are:

  • Legal Name (should be “Vanderbilt University by and through its Medical Center”, not your department or division)
  • Official Address (should be 1161 21st Avenue, South, Bldg/floor #, Nashville, TN 37232, not your department or division street address and not the GCM address)
  • Defined terms (parties, grant number, study name, and if the above is checked then look at: protocol, drugs, and devices)
  • Consideration (payment or other remuneration in exchange for the services performed)
  • Termination (must be mutual)
  • Indemnification
  • Flow down provisions of the Notice of Grant Award (NOGA) (It is the responsibility of the other party to tier the pertinent regulations into the subcontract.)
  • Governing law and Jurisdiction
  • Insurance (VUMC has a program of self-insurance)
  • Document retention (Per Federal Regulations the maximum is 3 years)
  • Best efforts (GCP, obey all laws, reciprocal)
  • Notices (GCM required, Business Matters and Technical Matters addresses optional but recommended)
  • Conflict of terms (if contract conflicts with attachments, exhibits or protocol, the contract terms must prevail)
  • Publication rights
  • Confidentiality
  • HIPAA
  • Intellectual Property
  • Patents
  • Data Ownership
  • Use of Names (this should be mutual)
  • Entire agreement
  • Amendments/No Assignments

Required Terms for Outgoing Federal Dollars

(When VUMC is the prime recipient of federal funds)

These are some of the terms required in a Outgoing Federal Subcontract and it’s based from our template.

  • Legal Name for the party in which we are subcontracting part of this project.
  • Term Dates (if no express date, make effective date the date of final signature)
  • Official Address for the other party.
  • Consideration (payment or other remuneration in exchange for the services performed) (If cost-reimbursement subcontract then please route a detailed budget. If fixed price subcontract then please route a payment schedule and the number of payments to be detailed in the subcontract.)
  • Notices (the contact information for the other party (name, address, phone and fax number)
  • Conflict of terms (we’d need to know if there is a protocol so that conflict language may be added to the subcontract)

Process Flowcharts for Federal Subcontracts