FDP Subaward Templates: Which One to Use

When a prime recipient of a federal grant passes part of the substantive scope of work to another organization, the resulting subaward agreement has to carry forward dozens of flow-down terms from the prime award while still reflecting the specific payment structure and jurisdiction of the subrecipient. Rather than each pair of institutions drafting that agreement from scratch, most US research institutions start from one of the standardized subaward templates published by the Federal Demonstration Partnership (FDP). This guide covers what the FDP template system is, why it exists, and how to choose between its three main variants — Cost Reimbursement, Fixed Amount, and Foreign.

Quick reference: which FDP template applies

Variant	Subrecipient location	Payment basis	Key limit
Cost Reimbursement	US	Actual allowable costs	None beyond the subaward’s own budget ceiling
Fixed Amount	US	Predetermined amount per milestone/deliverable	$500,000 cap plus prior agency approval (2 CFR § 200.333)
Foreign Cost Reimbursement	Non-US	Actual allowable costs	De minimis MTDC up to 15% if no negotiated rate (2 CFR § 200.414(f)); NIH uses a fixed 8% for its own awards
Foreign Fixed Amount	Non-US	Predetermined amount	Same $500,000/approval rule, plus export-control screening on what is shared

The sections below explain the reasoning behind each row, including where each dollar figure and rate actually comes from.

What the FDP subaward template system is

The FDP is a consortium of more than 230 US academic institutions and 10 federal funding agencies that develops consensus-based solutions to reduce research-administration burden (thefdp.org). Its Subaward Templates and Tools resource is a set of PDF-fillable model agreements that a pass-through entity (PTE — the prime recipient of a federal grant or cooperative agreement) can use to issue a subaward to a subrecipient organization, structured to align with the terms of Uniform Guidance, 2 CFR Part 200.

As of this writing, the current template family is:

FDP Cost Reimbursement Subaward (revised October 2025) — for US-based subrecipients reimbursed against actual allowable costs.
FDP Fixed Amount Subaward (revised October 2025) — for US-based subrecipients paid a predetermined amount tied to milestones or deliverables rather than actual costs.
FDP Foreign Cost Reimbursement Subaward (revised July 2025) — the cost-reimbursement structure adapted for a non-US subrecipient organization.
FDP Foreign Fixed Amount Subaward (revised July 2025) — the fixed-amount structure adapted for a non-US subrecipient organization.

FDP revises the templates periodically (a March 2024 update summary, for example, documents changes to invoicing-frequency language), so always pull the current version directly from the FDP site rather than reusing a saved copy from a prior cycle. FDP also publishes an accompanying FAQ document alongside the templates, with appendices covering required data elements and carryover guidance.

Both FDP-member and non-member institutions may use the templates as-is. FDP’s own guidance is explicit that these are optional model documents provided without warranty — the PTE remains fully responsible for ensuring the terms of its own prime award actually flow down into the subaward, and for whatever institutional legal review its own policies require. An institution that edits a template for its own use is directed to remove references to FDP from the resulting document.

Why the FDP standardized these templates

Standardization exists to cut down the time two institutions spend negotiating an agreement that, in substance, has to say the same thing regardless of which two institutions are involved: allowable-cost rules, reporting cadence, intellectual property, publication rights, and the specific clauses a federal award requires to flow down to a subrecipient. Renegotiating each of those terms bilaterally for every subaward is exactly the kind of duplicated, non-research-generating effort the FDP’s own research has quantified directly.

The FDP’s Faculty Burden Survey — fielded in fall 2005 across 73 FDP member institutions, with 6,081 responding faculty (Rockwell, S., “The FDP Faculty Burden Survey,” Research Management Review 16(2), 2009, pp. 29–44) — found that 42% of the time an average PI spent on a federally funded research project went to administrative tasks rather than the research itself. The survey attributed that burden not to one or two especially onerous requirements, but to the cumulative effect of many separate administrative demands layered on top of each other across agencies and institutions. A subaward negotiated clause-by-clause from a blank page is one contributor to that cumulative load; starting both sides from a shared, pre-vetted template is a direct, structural way to reduce it — not a complete fix for administrative burden, but a concrete instance of the FDP’s stated mission to reduce it.

FDP Cost Reimbursement Subaward: the default for federal cost-reimbursement subawards

This is the template most PTEs reach for first. The subrecipient is reimbursed for actual, documented, allowable costs incurred in performing its portion of the scope of work, up to the subaward’s total budget ceiling, following cost-reimbursement principles under Uniform Guidance. It is the appropriate default whenever the subrecipient’s own effort is difficult to price as a fixed deliverable in advance — most substantive research subawards fall into this category, particularly multi-year subawards with evolving scope.

Flow-down and monitoring obligations under 2 CFR Part 200, Subpart D apply directly: the PTE must make a subrecipient-versus-contractor determination for the relationship (2 CFR § 200.331), meet the requirements for pass-through entities including flow-down of applicable award terms (2 CFR § 200.332), and carry out ongoing subrecipient monitoring — risk assessment, financial oversight, and audit follow-up — for the life of the subaward.

FDP Fixed Amount Subaward: when a predetermined price fits better

Under a fixed-amount subaward, the subrecipient is paid a set amount tied to completing defined milestones or deliverables, not to documented actual costs. This trades the administrative overhead of cost-reimbursement accounting and detailed expenditure reporting for a simpler payment structure — appropriate where the subrecipient’s scope of work is well-defined enough to price up front (a specific analysis, a defined set of samples processed, a discrete technical deliverable), rather than open-ended research effort.

Fixed-amount subawards are a specific, bounded mechanism under Uniform Guidance, not a default option. Per 2 CFR § 200.333, a recipient may issue subawards on a fixed-amount basis, with prior written approval from the federal awarding agency, up to $500,000 per subaward — a threshold raised from $250,000 in the Office of Management and Budget’s April 2024 revision of the Uniform Guidance. Above that ceiling, or without the agency’s prior approval, a fixed-amount structure is not permitted and the subaward has to use cost reimbursement (or another permitted structure) instead. Fixed-amount subawards must also meet the general standards for fixed-amount awards at 2 CFR § 200.201, including that payments be based on meeting specific requirements of the award and not simply used to avoid the cost-reimbursement rules.

When this took effect, precisely. April 22, 2024 is when OMB published the revision in the Federal Register (89 FR 30046), not when it became binding on every award. Under 2 CFR § 200.110(a), these standards “become effective once implemented by Federal agencies” — so an individual awarding agency could adopt the revised $500,000 ceiling for its own awards ahead of the government-wide effective date of October 1, 2024. For a fixed-amount subaward issued in mid-to-late 2024, confirm which ceiling actually applied by checking the awarding agency’s own adoption date and the prime award’s issuance date, not by the April 22 publication date alone.

The foreign variants: subawards to non-US institutions

Both the cost-reimbursement and fixed-amount structures have a foreign counterpart — the FDP Foreign Cost Reimbursement Subaward and the FDP Foreign Fixed Amount Subaward — built for subrecipient organizations based outside the United States. The underlying payment logic (actual costs vs. predetermined amount) is the same as the domestic templates; what changes is a set of considerations that only apply once the subrecipient sits outside US jurisdiction:

Indirect cost rate. A foreign subrecipient frequently has no federally negotiated indirect cost rate. Under 2 CFR § 200.414(f), an organization that has never had a negotiated rate may elect a de minimis modified-total-direct-cost (MTDC) rate of up to 15% (raised from 10% effective for awards issued on or after October 1, 2024). NIH’s own policy, separately, reimburses foreign organizations and foreign components of a US award at a fixed 8% MTDC facilities-and-administrative rate without requiring a negotiated rate at all — a narrower, agency-specific figure that a PI should confirm against the specific funding agency’s current policy rather than assume applies universally.
Currency and invoicing. Where possible, PTEs are advised to obtain subrecipient budgets in US dollars to limit exposure to exchange-rate fluctuation, and to set invoicing frequency (commonly at least quarterly) with enough regularity that the PTE can monitor the subrecipient’s financial progress without a long lag.
Export control. Sharing controlled technology, technical data, or equipment with a foreign subrecipient can trigger US export-control obligations under the International Traffic in Arms Regulations (ITAR, 22 CFR Parts 120–130, administered by the State Department) or the Export Administration Regulations (EAR, 15 CFR Parts 730–774, administered by the Commerce Department’s Bureau of Industry and Security), independent of whatever the subaward’s payment structure is. This determination has to be made on the substance of what’s being shared, not assumed away by using the foreign template.

None of this changes the core subrecipient-versus-contractor or flow-down analysis under 2 CFR §§ 200.331–200.332 — a foreign subaward is still a subaward, subject to the same monitoring obligations as a domestic one, plus the considerations above.

Choosing a template: a practical decision path

Is this a subaward at all? Confirm the relationship is a subrecipient relationship (the other organization performs a defined portion of the substantive scope of work under its own PI and budget) rather than a procurement relationship for goods or services, per the 2 CFR § 200.331 factors. If it’s a procurement, none of these templates apply.
US or foreign subrecipient? That determines whether the domestic or foreign template family applies.
Cost reimbursement or fixed amount? Default to cost reimbursement unless the scope of work is well-defined enough to price as fixed milestones/deliverables, the total is at or under the $500,000 Uniform Guidance ceiling for fixed-amount subawards, and the federal awarding agency has given prior written approval for a fixed-amount structure on this award.
Pull the current version directly from the FDP subaward templates page rather than an institution’s saved copy, since FDP revises the templates periodically.

What the templates don’t replace

A standardized template lowers negotiation friction on the terms that are genuinely common across subawards; it does not remove the PTE’s own compliance obligations. The prime recipient still has to determine what terms from its own award are required to flow down, still owns subrecipient monitoring and risk assessment for the life of the subaward, and still has to apply its own institutional review (legal, export-control, human-subjects, or otherwise) before execution. Using an FDP template is a starting point for that process, not a substitute for it.

Who handles this in the office

This page assumes someone is choosing a template, but at most institutions that isn’t one person’s whole job. The subrecipient-versus-contractor determination, template selection, and flow-down review are normally Sponsored Programs / Office of Grants and Contracts work — typically a subaward or grants-and-contracts officer, not the PI. Prior agency approval for a fixed-amount structure under 2 CFR § 200.333 is usually requested by that same office, not negotiated by the PI directly with the sponsor. Export-control screening on a foreign subaward is ordinarily a separate referral to the institution’s export-control officer, triggered by the subaward officer — not something to skip because “it’s just a subaward.” Office titles and the exact division of labor vary by institution, but template selection, agency approval, and export-control screening are usually three different people’s sign-off, not one.

What a Single Audit tests here

The sections above state the monitoring obligation at 2 CFR § 200.332; auditors test it concretely. Under 2 CFR Part 200, Subpart F, a pass-through entity’s subrecipient monitoring is a standard Single Audit compliance area. Tied directly to 2 CFR §§ 200.331–200.332, the three things an auditor checks against the record are:

A documented subrecipient-versus-contractor determination exists for each subaward — not an assumption that was made and never written down.
The subaward document actually contains the required flow-down terms from the prime award — not a generic template left unedited.
Risk assessment and monitoring activity — desk reviews, site visits, or follow-up on the subrecipient’s own Single Audit findings — is documented for the life of the award, not only at issuance.

A template that hasn’t been updated to reflect the prime award’s specific terms is a documentation gap even when the underlying subrecipient relationship was assessed correctly.

Common failure modes

Reusing an old saved copy of a template instead of pulling the current version — FDP revises these on its own schedule (October 2025 for the domestic templates, July 2025 for the foreign ones, per the revision dates above), and a stale copy can carry outdated invoicing or reporting language.
Issuing a Fixed Amount subaward above $500,000, or without the awarding agency’s prior written approval — both are required by 2 CFR § 200.333, not optional formalities.
Applying the NIH-specific 8% foreign F&A rate to a non-NIH award, or vice versa — an easy agency-to-agency copy error, since the figure and the 15% de minimis rate look interchangeable at a glance but are not.
Editing a template’s substantive terms but leaving FDP’s name or logo in the document — FDP’s own guidance asks institutions to strip references to FDP from an edited template, and leaving them in on a materially altered document misrepresents it as an unmodified FDP form.

Subaward vs. MTA vs. data sharing agreement

A subaward is a funding instrument — it moves federal award dollars to another organization to perform research. It’s a distinct instrument from the two other cross-institutional agreement types most often confused with it:

A Material Transfer Agreement (MTA) governs the transfer of physical research materials (cell lines, reagents, biological specimens) between organizations — no funding necessarily changes hands, and the receiving institution isn’t performing a scope of work for the provider. See the CASRAI guide on the MTA process.
A Data Sharing Agreement (DSA) governs the terms under which datasets move between collaborators or institutions — again, independent of whether federal award funds are being subcontracted. See the CASRAI guide on data sharing agreements between collaborators and institutions.

A single collaborative project can involve all three at once — a subaward funding a partner institution’s portion of the work, an MTA covering a reagent that partner needs, and a DSA governing how the resulting dataset is shared back — each governed by its own agreement, not one document doing all three jobs.

Where each of these requirements is written down

Requirement	Authority	Where to read it
Subrecipient-vs-contractor determination	2 CFR § 200.331	eCFR § 200.331
Flow-down and pass-through-entity duties	2 CFR § 200.332	eCFR § 200.332
$500,000 fixed-amount subaward ceiling	2 CFR § 200.333	eCFR § 200.333
15% de minimis indirect-cost rate	2 CFR § 200.414(f)	eCFR § 200.414
April 2024 revision publishing these figures	OMB, 89 FR 30046	Federal Register, doc. 2024-07496

When this last changed, and how you find out next time

The thresholds above are current as of October 1, 2024. They are not permanent: OMB revised 2 CFR 200 on April 22, 2024, published in the Federal Register at 89 FR 30046, and the figures in the tables above are the post-revision ones.

OMB publishes every change to the Uniform Guidance in the Federal Register, and the Federal Register is one of the sources Regulatory Radar checks every day — so 2 CFR 200 is one of the few subjects where CASRAI reads the primary publication venue itself rather than waiting for somebody’s summary. It does not watch the NIH Guide, and it does not watch thefdp.org’s own template-revision schedule — the FDP-specific October 2025 and July 2025 revision dates above come from reading the FDP site directly, not from anything Radar monitors.

Ask CASRAI what 2 CFR 200 currently requires for subrecipient monitoring and indirect-cost documentation on an FDP subaward — it answers from an indexed corpus it re-checks daily and cites the passage it used, so you can open the source and check it. Two questions a day are free while you are signed out, no account and no card. Regulatory Radar is $29 a month for 150 a day, a subscriber dashboard, API keys and MCP access. Everything CASRAI publishes, including this page, stays free to read.

Your first free question is the one in that link. Save the second for the part that depends on your own award — your subrecipient’s actual negotiated rate, whether your awarding agency had adopted the revised thresholds yet on the date your award issued, or the specific flow-down terms in your prime award.

Frequently asked questions

Our foreign subrecipient already has its own federally negotiated indirect cost rate — does that override the 15% de minimis option under 2 CFR § 200.414(f)?

Generally yes. The de minimis MTDC rate at 2 CFR § 200.414(f) is available specifically to an entity that has never received a negotiated indirect cost rate — if the subrecipient already holds one, that negotiated rate is the applicable rate for the subaward, not the de minimis election, unless the specific award or agency policy says otherwise. Document the subrecipient’s own negotiated indirect cost rate agreement (NICRA), the rate actually applied on the subaward budget, and — for an NIH award — whether NIH’s fixed 8% foreign policy supersedes both, in the subaward file. That documentation is exactly what a Single Audit reviewer checks under 2 CFR §§ 200.331–200.332 (see “What a Single Audit tests here” above): a rate applied without a record of which authority justified it is the kind of gap auditors flag even when the rate itself turns out to be correct.

Are institutions required to use the FDP subaward templates?

No. They’re optional model documents. Uniform Guidance doesn’t mandate a specific subaward form — it mandates the substantive terms (flow-down, monitoring, cost principles) that any subaward agreement has to satisfy. The FDP templates are a widely adopted way of meeting those substantive requirements without drafting from scratch, not a federal requirement in themselves.

Can a non-FDP-member institution use them?

Yes — FDP’s own guidance states both member and non-member institutions may use the templates as-is. An institution that edits a template for its own purposes is expected to remove FDP references from the resulting document rather than present an edited version as an official FDP template.

What’s the dollar threshold for a fixed-amount subaward under Uniform Guidance?

$500,000 per subaward, with prior written approval from the federal awarding agency, per 2 CFR § 200.333 — published in OMB’s April 22, 2024 Federal Register revision of Uniform Guidance (89 FR 30046) and effective government-wide October 1, 2024, though an individual awarding agency could adopt it earlier under 2 CFR § 200.110(a). Up from a $250,000 ceiling under the prior version of the rule.

Do foreign subrecipients need a federally negotiated indirect cost rate?

Not necessarily. A foreign organization without a negotiated rate can generally use the de minimis MTDC rate available (up to 15% since October 1, 2024, raised from 10%) under 2 CFR § 200.414(f); some agencies apply their own fixed rate instead — NIH, for example, reimburses foreign organizations and foreign components at a fixed 8% MTDC rate rather than requiring a negotiated rate. Confirm the specific funding agency’s current policy before assuming either figure applies.

Is a subaward the same thing as a subcontract?

In practice the terms are often used loosely and interchangeably in research-administration conversation, but the operative distinction under Uniform Guidance is subrecipient vs. contractor, not the label on the document. What matters is whether the other organization is performing a portion of the substantive scope of work with its own PI and budget (a subrecipient relationship, appropriately documented as a subaward) or simply providing goods or services to the prime (a procurement relationship, documented as a contract) — see 2 CFR § 200.331 for the specific factors used to make that determination.

FDP Subaward Templates: Cost Reimbursement, Fixed Amount, and Foreign Variants