Subaward Pre-Award or Just-in-Time

While awaiting the sponsor’s funding decision and/or when funding is imminent, the UC Berkeley Principal Investigator (PI), with help from their Research Administrator, should check the following.

Is just-in-time information needed from the Subrecipient?

Public Health Services (PHS) Prime Awards, and sometimes other sponsors, request just-in-time information when an award to UC Berkeley is imminent. Get ready to collect just-in-time information from the Subrecipients, which may include:

Updated Other Support documents for Subrecipient Key Personnel.
Revised Budgets and Budget Justifications.
Current Human Subjects Training certificates.
IRB approval of the Subrecipient’s Human Subjects Protection protocol.
ACUC approval of the Subrecipient’s Animal Use protocol.

Is the Subrecipient still on track to participate in the research?

When the sponsor’s funding decision time comes near, check in with the Subrecipient PI to ensure that:

They are still on track to participate in the research.
They are still working at the same Subrecipient institution.
They agree with any recent changes to the Statement of Work, budget and performance period.
They provide an updated Subrecipient Commitment Form when changes to their Statement of Work or budget are significant or substantive, or if the form was signed more than 12 months ago.

Changes to any of the above will require you to obtain an updated Subaward Proposal from the Subrecipient institution, and may require Sponsor approval.

Is the collaborator truly a Subrecipient?

Use the time between proposal submission and the sponsor’s funding decision to double check that your collaborator is truly a Subrecipient, using the Subrecipient vs. Supplier Wizard.

Contact the SPO CGO who handled the proposal if any corrections are needed.

Is the Subrecipient registered in the System for Award Management?

Subrecipients supported under federal funding must register in the System for Award Management (SAM). SPO will check for this when processing the subaward request. Subrecipients supported under non-federal funding are also encouraged to register in SAM, to help SPO expedite risk assessments.

If the Subrecipient is not registered in SAM, encourage them to do so while awaiting the sponsor’s funding decision.

Does the Subrecipient have a Dun and Bradstreet (DUNS) number?

SAM registration requires the Subrecipient to have a Dun and Bradstreet (DUNS) number, which is a nine-digit number, issued by Dun and Bradstreet (D&B). SPO will check for this when processing the subaward request. (Note that, as of April 2022, Subrecipients must use a Unique Entity Identifier (UEI), assigned by the System for Award Management, in place of a DUNS.)

If the Subrecipient does not have a DUNS number, encourage them to do obtain one while awaiting the sponsor’s funding decision.

Does the Subrecipient have a sponsor-compliant conflict of interest policy?

UC Berkeley expects Subrecipients to have their own sponsor-compliant conflict of interest (COI) policy in place before UC Berkeley issues their subaward. SPO will check for this when processing the subaward request. Subrecipients without such a policy should start establishing one soon after SPO submits its proposal to the sponsor. (Other UC Campuses and Federal Demonstration Partnership (FDP) Expanded Clearinghouse participants have such sponsor-compliant COI policies, by default.)

While awaiting the sponsor’s funding decision, review the Subrecipient Commitment Form to see how they answered Question 5 (Conflict of Interest). If the Subrecipient indicated that they do not have an active and enforced COI policy:

Advise the Subrecipient that UC Berkeley will not issue them a subaward until they have a sponsor-compliant COI policy in place.
- For subawards supported by National Science Foundation (NSF), tell the Subrecipient to consult the NSF COI policies for guidance on how to create a COI policy.
- For subawards supported by other sponsors that have adopted the NSF COI policy, or other federal sponsors with financial disclosure requirements, tell the Subrecipient to consult the COI requirements in the sponsor’s proposal application guidelines.
- For subawards supported by PHS and other sponsors that have adopted the PHS financial disclosure requirements, direct the Subrecipient to the FDP Model Financial Conflict of Interest Policy and Model Disclosure Form provided by the Federal Demonstration Partnership Conflict of Interest Subcommittee. This model policy can help Subrecipients create their own Financial Conflict of Interest policy. Additionally, recommend that the Subrecipient certify their PHS compliance by registering at the FDP FCOI Clearinghouse.
Ask the Subrecipient to provide an updated Subrecipient Commitment Form once they have established their sponsor-compliant COI policy. Include this updated form when submitting your Subaward Request to SPO.

For the next step in the process, see Subaward Setup .

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.