Subrecipient Commitment Form Guidance
As outside organization, acting as Subrecipients to UC Berkeley, your institution must provide the appropriate Subrecipient commitment form, at the proposal stage and before UC Berkeley will issue a subaward. The type of commitment form you provide depends on your institution.
| Multiple Campus (MCA) Commitment Form | FDP Expanded Clearinghouse Participant Commitment Form | Subrecipient Commitment Form |
|---|---|---|
| Use this form if your institution is: Another UC Campus, the UC Division of Agriculture and Natural Resources, or the UC Office of the President | Use this form if your institution is: A Federal Demonstration Partnership (FDP) Expanded Clearinghouse Member | Use this form if your institution is: Any other type of Subrecipient |
| Multiple Campus (MCA) Commitment Form Completing the Multiple Campus (MCA) Commitment Form | FDP Expanded Clearinghouse Participant Commitment Form Completing the FDP Expanded Clearinghouse Participant Commitment Form | Subrecipient Commitment Form Completing the Subrecipient Commitment Form |
For subagreements to Lawrence Berkeley National Lab (LBNL), a Subrecipient Commitment Form is not required. LBNL subaward proposals to UC Berkeley must be routed through LBNL’s Strategic Partnership Office. That Office will provide a “Funds-in Memorandum Agreement Information Sheet,” documenting their institutional endorsement, and will include it as part of their subaward proposal packet. Contact your SPO Contract and Grant Officer if further instruction is needed.
The information you provide on your commitment form helps UC Berkeley’s Sponsored Projects Office (SPO) verify your institution’s eligibility as a Subrecipient and confirm that your institution’s Authorized Organizational Representative (AOR) has approved the information contained in UC Berkeley’s proposal.
The information on your commitment form also helps SPO conduct the required risk assessments for your institution, at the time SPO issues the subaward.
The information on your institution’s commitment form is valid if signed by your AOR within the past 12 months.
Determining if You are a Subrecipient
The UC Berkeley PI and Subrecipient institution should both verify that the intended Subrecipient is acting as a Subrecipient, and not as a vendor/supplier. See the See the Subrecipient vs. Supplier Wizard. For example:
| Vendors/Suppliers typically… | Subrecipients typically… |
|---|---|
| Provide standard goods and services that are also provided to other customers. | Follow a Statement of Work that is unique to the project and represents a substantial intellectual contribution to the project. |
| Provide a standard part needed to fabricate a piece of equipment. | Work collaboratively with the UC Berkeley PI to design, test, and develop a piece of equipment. |
| Sell data or specimens to UC Berkeley; or analyze data or specimens for UC Berkeley, in a standard way as provided to other customers. | Help design a unique research protocol, collect data, analyze the collected data, and interpret analysis results. |
| Follow the UC Berkeley PI’s direction or instructions, without any programmatic decision making. | Identify an individual (the Subrecipient PI) who will collaborate in programmatic decision making and help the UC Berkeley PI to achieve the project’s goals. |
As a Subrecipient you will be expected to:
- Conform to all of the compliance requirements in the Prime Award that are pertinent Subrecipients (e.g., effort reporting on federal awards, Federal terms and conditions, etc.).
- Provide a complete copy of, or URL link to, your most recent federal audit report.
YOU SHOULD NOT ACCEPT THE ROLE OF A SUBRECIPIENT IF YOUR INSTITUTION IS NOT PREPARED TO ACCEPT SUCH TERMS.
The final determination on whether an outside collaborator is acting as a Subrecipient or a supplier and the acceptability of any proposed Subrecipient will be made only after:
- UC Berkeley receives the sponsor’s Prime Award;
- The UC Berkeley PI requests that a subaward be established;
- SPO determines that the Statement of Work is appropriate for a Subrecipient relationship with the outside collaborator; and
- SPO conducts a risk assessment of the proposed Subrecipient.
SPO will not issue subawards to Subrecipients that pose an unacceptable risk to UC Berkeley.
Instructions for Completing the Subrecipient Commitment Forms
Your commitment form must be completed by someone who:
- Is knowledgeable about your institution’s business processes.
- Possesses information about the Statement of Work your institution’s Principal Investigator/Project Director will carry out.
Your commitment form must be approved and signed by your institution’s Authorized Organizational Representative (AOR). This is the individual with the authority to legally bind your institution in administration matters related to grants, contracts and cooperative agreements. It should not be the head of a sub-unit within your institution, unless that individual has the written delegated authority to serve as an AOR.
See the detailed instructions for completing each form:
- Completing the Subrecipient Commitment Form
- Completing the FDP Expanded Clearinghouse Participant Commitment Form
- Completing the Multiple Campus (MCA) Commitment Form
If you have questions, please contact the Subaward Team at subcontracts@berkeley.edu. If you have a suggestion on how we might improve SPO’s subaward services, please drop it in the Subaward Suggestion Box.