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  • The Uniform Guidance requires prior approval for all fixed price Federal subawards and sets a threshold of $150,000 (also known as the Simplified Acquisition Threshold). 
  • Prior written approval from the agency is required.
  • Subcontracts under Federal Awards: Contracts over the Simplified Acquisition Threshold ($150,000) must address contract breach.  Contracts in excess of $10,000 must address termination for cause. (Appendix II to Part 200 – Contract Provisions for Non-Federal Entity Contracts under Federal Awards). 



Action Plan

  • Update materials regarding prior written approval requirement. (Shannon Robinson)
  • Modify pre-award process to ensure prior approval is obtained before issuing fixed price subawards. (Todd Travis)
  • Review specific agency guidance related to subawards as they are released and identify impact (Shannon Robinson
  • Recommend modifying the pre-award process to add language in the proposal budget justification for fixed award as follows (Todd Travis

The subaward to _______ documented in this proposal meets the criteria described in Subpart C-200.201(b) and Clarkson University is therefore requesting prior agency approval of this Fixed Price Subaward. The University will consider this subaward approved, if an award is made and no contrary guidance from the agency is included in the award notice.

  • Contracts for subrecipients of federal awards administered by Clarkson will include specific terms and conditions applicable to the Uniform Guidance. (Shannon Robinson)






  • Updating of Division of Research reference material and internal work instructions to be completed. 
  • Review of final agency guidelines will be done as they become available.