Subaward Monitoring

After a subaward is fully executed, the UC Berkeley Principal Investigator (PI), with help from their Research Administrator, is responsible for monitoring Subrecipients to ensure they comply with applicable federal regulations and the terms of both the Prime Award and the subaward.

The following is a summary of recommended steps for monitoring and managing subawards.

Review the subaward document

It is important to review a subaward’s terms and conditions, so you know what is expected of the Subrecipient. Generally, a subaward will include:

  • The subaward agreement itself, containing the terms and conditions with which the Subrecipient must comply;
  • The Subrecipient’s Statement of Work, which determines the work the Subrecipient has agreed to do;
  • The Subrecipient’s budget information, which determines how the Subrecipient is allowed to expend funds;
  • The Prime Award, containing the Sponsor’s terms and conditions with which both UC Berkeley and the Subrecipient must comply;
  • Other documents (e.g., invoicing or reporting templates, multi-PI leadership plans, data-sharing plans) that pertain to requirements in the subaward.

Pay particular attention to:

  • The invoicing and reporting requirements. The Subrecipient’s reporting and invoicing are your key ways of tracking how Subrecipients are doing.
  • The Subrecipient’s Statement of Work. This is the “yard stick” against which you will measure the Subrecipient’s technical performance.
  • The Subrecipient’s budget. Invoicing should be compared to the subaward budget, to ensure that the Subrecipient’s spending is what you expected.

SPO issues subawards in several different formats:

  • Multiple-Campus Awards (MCAs) are used only for subawards to University of California entities, including other UC Campuses (e.g. UCLA, UCSF, etc.), the UC Division of Agriculture and Natural Resources (UCANR), and the Office of the President (UCOP), in accordance with Research Policy Analysis & Coordination (RPAC) Guidance Memo 14-18.
  • Federal Demonstration Partnership (FDP) Subawards are used for most subawards under federal funding.
  • A “long-form” subaward format is used for subawards under non-federal funding, including subawards under State of California Prime Awards; or for subawards under federal funding when the FDP Subaward template is not appropriate.
  • A Memorandum Agreement format is used for subawards to Lawrence Berkeley National Laboratory.

If you have any questions about the terms in particular subaward, contact SPO at subcontracts@berkeley.edu.

Maintain an active collaboration with the Subrecipient PI

Subrecipients are partners in UC Berkeley’s research, so it is important to establish good communication from the beginning. The UC Berkeley and Subrecipient PIs should communicate regularly about project progress. Questions to ask continuously during the life of a subaward include:

  • Is Subrecipient’s work progressing according to schedule?
  • Is the Subrecipient PI alerting UC Berkeley to any logistical problems, in a timely manner?
  • Is the Subrecipient PI responsive to communications from UC Berkeley?
  • Are the Subrecipient’s compliance requirements up to date? (e.g., Is the Subrecipient providing documentation related to sponsor-specific or program-specific requirements and assurances, such as approvals for animal use, human subjects, and biohazards?)
  • Is the Subrecipient PI or other Key Personnel planning to change institutions in the future?

Monitor the Subrecipient’s technical performance

Most subawards include technical reporting requirements. Often these are for annual and final reports, or for deliverables/milestones to be accomplished by set due dates. The Subrecipient’s reporting informs UC Berkeley’s reporting to the sponsor.

The Subrecipient should always direct their reporting to the UC Berkeley PI, who must review it to check for satisfactory progress. Questions to ask when reviewing a Subrecipient’s technical performance include:

  • Is the Subrecipient sticking to their Statement of Work?
  • Are deliverables/reports being provided according to the required due dates?
  • Is the content and form of the deliverables/reports satisfactory?
  • Is the Subrecipient reporting to UC Berkeley in a way that easily enables us to complete our reporting to the sponsor?

Monitor the Subrecipient’s spending

Subaward monitoring also includes keeping track of costs that Subrecipient is invoicing for, compared to the approved budget. A Subrecipient’s spending must be:

  • No greater than the total funds obligated, to date;
  • In general accordance with the approved budget; and
  • Incurred only during the authorized performance period.

Subawards always include invoicing requirements. Subaward terms usually request monthly invoicing, but may allow quarterly invoicing in special cases.

The Subrecipient’s invoicing is tied to UC Berkeley’s invoicing of the sponsor. The Subrecipients are usually required to submit detailed line-item invoices, with back-up documentation provided to UC Berkeley’s Financial Contact, upon request. The UC Berkeley PI should always be involved in reviewing and approving invoice, and should only approve invoices that provide detail sufficient to show that expenditures are allowable, allocable, and reasonable. Invoices that don’t meet this requirement should be returned to the Subrecipient for correction or clarification.

UC Berkeley Contracts and Grants Accounting (CGA) should only pay Subrecipient invoices that the UC Berkeley PI has approved. Questions to ask when reviewing a Subrecipient’s invoices include:

  • Do the invoices provide enough detail to show how the funds were expended?
  • Do invoices reflect allowable, allocable, and reasonable costs?
  • Is the Subrecipient spending funds according to the budget and project time lines?
  • Is the Subrecipient verifying committed cost sharing? (if applicable)
  • Is the Subrecipient providing carryover requests? (if applicable)

Note that CGA also provides guidance on Subrecipient monitoring.

Agency-Specific Monitoring

National Institutes of Health (NIH)

For International Subrecipients under NIH: Effective January 1, 2024, PI ensures subrecipient access (electronic access permissible) to copies of all lab notebooks, all data, and all documentation associated with the research as described in the progress report to the primary funding recipient and in alignment with progress report submission requirements, but on no less than an annual basis per NIH GPS 15.2.1.
  • PI should verify access and document the location of materials provided by the subrecipient, retaining documentation and access location for a period of three (3) years from the date of submission of the grant’s final financial report.

Know when it’s time to amend a subaward

Most subawards will need to be amended (modified) during their lifetime. Understanding when amendments are usually needed will help you request them in time to avoid work delays caused by late amendments.

See Subaward Amendment for details about when and how to amend Subawards.

Alert SPO of problems with the Subrecipient

If you see that a Subrecipient is not complying with the terms of their subaward, spending funds as expected, or performing work as expected, communicate this right away to the Subrecipient’s PI. Addressing problems or misunderstandings early on, helps avoid larger problems later.

If the Subrecipient is not responsive in addressing problems or deficiencies, alert SPO by emailing the Subaward Team at subcontracts@berkeley.edu. SPO will step in to help amicably resolve the problems, before taking any stricter measures.

For the next steps in the process, see Subaward Amendment , Subaward Suspension or Early Termination , or Subaward Closeout .

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.

 

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