Working with Subrecipients
The following is a quick overview of the steps that principal investigators (PIs) need to take at the proposal and award stages to involve one or more subrecipients in a sponsored project at UC Berkeley. To make sure your subagreements are processed efficiently, please see Subagreement Pathways: The Slower Track vs. the Faster Track.
Beginning August 2016, UC Berkeley is participating in the Federal Demonstration Partnership (FDP) Expanded Clearinghouse Pilot. This pilot is testing the use of on-line entity profiles to decrease the amount of duplicate information collected from potential subrecipient institutions. Participating pilot institutions will not fill out the full three-page Subrecipient Commitment Form. Instead, participating institutions must complete the one-page FDP Pilot Subrecipient Project Information sheet. See FDP Expanded Clearinghouse - Subrecipients for more information.
The Proposal Stage
1. Before budgeting for a subrecipient, first determine if the collaborator you propose to work with is truly a subrecipient. For help in determining if your collaborator is a true subrecipient, consult the Subrecipient vs. Supplier Wizard. Failure to categorize subrecipients and suppliers properly can lead to delays in processing funds to these entities.
2. The PI should ask each potential subrecipient to complete a UCB Subrecipient Commitment Form or FDP Pilot Subrecipient Project Information sheet. This must be submitted to SPO at the proposal stage. The information will be considered valid for 12 months from the date of the form is signed by the subrecipient’s authorized official.
3. Include the following subrecipient documents as part of your proposal to the sponsor.
Proposals will not be endorsed by institutional officials at UC Berkeley until these elements are on file.
- Subrecipient’s Statement of Work (SOW), including a clear description of the work to be performed, the proposed timelines and deliverables, biosketches of subrecipient key personnel, etc.
- Subrecipient’s Budget and Budget Justification, including the subrecipient’s direct and indirect costs, calculated using the subrecipient’s approved facilities and administrative (F&A) and fringe benefit rates, and verifying any committed cost sharing.
- If one or more Subrecipients (individually or collectively) will be receiving the majority of the funds awarded to UC Berkeley, the Berkeley PI must complete and submit a Request to Subaward the Majority of Project Funds to SPO as a Phoebe Proposal Attachment.
4. If the PI intends to subaward 75% or more of the funds awarded to UC Berkeley, the PI must complete and submit a Request to Subaward the Majority of Project Funds Form to SPO as a Phoebe Proposal Attachment. This form is not required for Multiple Campus Awards (MCAs) to sister campuses within the UC system. This form also may be requested if SPO has any questions about the proposed subaward relationship.
5. If the prime is a contract, you must include:
- A Fair and Reasonable Cost Analysis and Sole Source Justification: Subawards Under Contracts form, signed by UC Berkeley’s PI. The PI must select a subrecipient based upon his/her assessment of the potential subrecipient’s ability to perform the research work successfully. This includes an analysis of the subrecipient’s past performance, technical resources and financial viability, and an assessment of the reasonableness of the subrecipient’s proposed costs in light of the work to be performed. To meet audit requirements, UC Berkeley is required to retain documentation of this latter assessment for subawards proposed under a contract. PIs are responsible for documenting this assessment via completion and submission of the Fair and Reasonable Cost Analysis for each proposed subrecipient.
Any exceptions to the requirements outlined above should be discussed with Sponsored Projects Office staff. If appropriate and acceptable documentation is not provided in a timely manner, UC Berkeley may be unable to endorse and submit the proposal.
The Award Stage
1. Submit a Request for Subaward and Request to Amend Existing Subaward to the following email address: email@example.com. Note incomplete request forms will be returned to the sender and will delay processing of subaward/s. See Subaward Request Form Instructions for more information.
2. If the Berkeley PI needs to change the subrecipient’s scope of work or budget submitted with the proposal, the PI should first discuss this with the subrecipient and make sure the subrecipient agrees with these changes.
3. If more than 12 months have passed since the subrecipient’s authorized official signed the UCB Subrecipient Commitment Form or FDP Pilot Subrecipient Project Information, please ask the subrecipient to review and update the form; then forward the updated form to firstname.lastname@example.org. Note: If the Subrecipient Commitment Form or FDP Pilot Subrecipient Project Information submitted with the proposal is still current (signed within the last 12 months), there is no reason to submit another form.
Special Procedures for “To be Determined” (TBD) and After-the-Fact Subrecipients
During award set up, SPO will assign subaward numbers to any TBD subrecipients listed in the proposal, and the TBD subrecipients with subaward numbers will be listed in the “Pending Subagreements: PI Action Required” section of the Phoebe Award Summary (PAS) unless prior approval of subrecipients is required by the sponsor.
When it is time to issue a subaward, the PI/CSS RA must submit a Request for Subaward and Request to Amend Existing Subaward to email@example.com. The request form should be complete and include:
- The official name of the former TBD subrecipient;
- A unique (unused) TBD subaward number from the PAS;
- All of the normal subrecipient back-up information required for subrecipients at the proposal stage.
Note: When sponsor prior approval of subrecipients is required, TBD subrecipients will be listed on the PAS without subaward numbers. When this is the case, the PI/CSS RA will need to submit all of the normal subrecipient back-up information to the SPO Contract and Grant Officer (CGO) that processed the proposal/award. The CGO will then issue a new PAS with each sponsor approved subrecipient listed by name with an assigned subaward number. The PI/CSS RA can then submit a Request for Subaward and Request to Amend Existing Subaward to firstname.lastname@example.org in the customary manner.
When a PI decides that a subrecipient is needed to carry out a portion of Berkeley’s scope of work after the award is made, i.e. the subrecipient is not listed by name or as a TBD in the proposal, the subrecipient is considered to be an “after-the-fact” subrecipient.
To add an after-the-fact subrecipient to an existing Berkeley award, the PI/CSS RA must submit all of the normal subrecipient back-up information required at the proposal stage to the SPO CGO that negotiated the award. The CGO then will obtain sponsor approval for the after-the-fact subrecipient if such approval is required by the sponsor. SPO then will issue a new PAS that lists the after-the-fact subrecipient with an assigned subaward number.
The PI/CSS RA then can use the assigned subaward number to submit a Request for Subaward and Request to Amend Existing Subaward to email@example.com. Note: The request form must be complete and include:
- The official name of the after-the-fact subrecipient
- The assigned subaward number from the PAS
- A check in the box in the upper right hand corner of the request form indicating that this is an after-the-fact subrecipient. Checking this box will alert the SPO subaward team that the CGO has already collected all of the required back up information for the subrecipient.
Subaward Guide and FAQs
Please consult the UC Berkeley Subaward Guide for detailed answers to a variety of frequently asked questions about working with subrecipients.
UC Berkeley Subaward Guide Contents:
- What is a subaward?
- Is a subrecipient form needed when proposing a subaward with another UC campus?
- Who is responsible for monitoring a subrecipient?
- Preaward stage by task/responsibility
- Award stage by task/responsibility
- Subaward monitoring stage by task/responsibility
- When does the monitoring of subrecipients begin?
- Why is a Subrecipient Commitment Form needed before an award is issued?
- How is the Subrecipient Commitment Form used?
- What other subaward documents are required at the proposal stage?
- What actions are required for subawards at the proposal stage?
- After an award is made, how is a subaward established?
- After an award is made, how can a PI add a subrecipient that was not named in the proposal?
- Facilitating subagreements
- What is required if the PI wants to provide a subrecipient with one or more advance payment/s?
- Subrecipient monitoring
- How can a subaward be changed/amended?
- How is a subaward closed out?
- Do you have a suggestion on how we might improve SPO’s subaward services?