Subawards to Foreign Entities

Page Updated: May 1st, 2018

Required Registrations

Any foreign entities that will receive federal funds need to be registered in the System for Award Management (SAM) and have a DUNS number. SAM registration must be renewed annually. In order to register with SAM, international organizations must also obtain a NATO Commercial and Governmental Entity (NCAGE) code.

In addition, the foreign institution must be registered in NIH Commons if collaborating on an NIH funded project. If the person at the foreign institution will be a PI on UW-Madison's proposal for a multi-PI submission, they must be affiliated in Commons with their institution with the PI role.


The Uniform Guidance allows foreign subrecipients with federally negotiated rates to use those rates, although few foreign entities have such rates. If no negotiated rate exists, NSF allows foreign organizations to recover indirect costs at the 10% de minimis MTDC rate; NIH allows an 8% MTDC indirect cost rate for foreign organizations. Please always read the sponsor's guidelines on allowable F&A costs for foreign institutions.

When possible, obtain budgets in USD to alleviate issues with exchange rate fluctuation.

Many foreign countries are subject to a Value Added Tax (VAT) that is levied on products, materials, and services purchased in lieu of sales tax. While VAT is generally considered an allowable cost according to the Uniform Guidance, these costs are often unknown during the proposal stage when the budget it developed. As such, the subrecipient should be responsible for these types of taxes and similar fees.

Terms and Conditions

The FDP provides a checklist of additional terms and conditions to be considered for foreign subawards that may apply to foreign subawards. Please note that prior to the issuance of a subaward to a foreign entity, RSP will consult appropriate institutional officials to ensure the subaward meets institutional, sponsor and project requirements.

In cases where foreign entities may need advance payment to start work on the project, we will need to establish clear expectations as it relates to progress reporting, financial reporting, and invoicing against the advance.