Dear Colleagues,

How are you incorporating the new Uniform Guidance (UG) data elements into your lower tier subaward agreements? This would be the situation when your institution receives federal flow through funds from a Pass Through Entity (PTE) and will pass a portion on to a third lower tier institution.

FDP has provided a new template for 1st tier subawards where my institution is the PTE and we have received funding directly from a federal agency. But I’m not sure how to reflect the required data elements to a 2nd tier entity.

For example, data element #1. (x) Name of Federal awarding agency, pass-through entity, and contact information for awarding official. Do you consider the awarding official to be the federal awarding official, or the awarding official at the 1st pass through entity, or the awarding official at your own institution?

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