Subaward Process at Berkeley
Overview
A subaward is an agreement between UC Berkeley and an outside organization (a “Subrecipient”) that performs a portion of UC Berkeley’s sponsored project.
- Subrecipients share in programmatic decision making with UC Berkeley and work collaboratively with UC Berkeley researchers to carry out the sponsor-funded work.
- Subrecipients are subject to the same Prime Award terms and conditions as is UC Berkeley.
- Subrecipients commonly include, but are not limited to, institutions of higher education (colleges and universities), non-governmental organizations, non-profit organizations, for-profit organizations, and municipalities (State, County and City offices).
A Subrecipient differs from a Supplier/Vendor and is subject to different policies and procedures, and different budgeting requirements. It is important to correctly determine whether an outside organization is acting as Subrecipient or a Supplier/Vendor. Use the Subrecipient vs. Supplier Wizard to make this determination at the proposal development stage.
UC Berkeley’s Sponsored Project Office (SPO) issues outgoing subawards funded by grants, cooperative agreements and contracts received through SPO. These transactions can support organized research, instruction, or other sponsored activities.
SPO does not handle outgoing subawards funded by:
- Industry sponsors: UC Berkeley’s Industry Alliances Office (IAO) handles all subawards supported by industry funding.
- Gift or discretionary funding: UC Berkeley’s Supply Chain Management (SCM) office handles subawards supported by gift or discretionary funding as procurement transactions.
Who Does What?
The following is a general overview of the roles for those involved in the subaward process:
- UC Berkeley Principal Investigator (PI)
- Identifies the appropriate collaborating outside organizations (not individual consultants) to serve as Subrecipients under the sponsored project.
- Manages and monitors the Subrecipient’s performance and spending on the project, in accordance with the subaward terms.
- Notifies SPO of any problems or issues with the Subrecipient’s performance on the project.
- Departmental Research Administrator
- Helps the UC Berkeley PI obtain the Subrecipient’s proposal and integrate it into UC Berkeley’s proposal submitted to the sponsor.
- Helps the UC Berkeley PI submit a request to SPO, to issue the subaward.
- Establishes a BearBuy Purchase Order, for the subaward.
- Monitors the Subrecipient’s spending and invoices.
- Helps the UC Berkeley PI request amendments to the subaward.
- Helps the UC Berkeley PI to close out the subaward.
- Sponsored Projects Office (SPO), Contract and Grant Officers
(CGOs)
- Assigns subaward numbers to new subawards.
- Corresponds with sponsors about any subaward-related approvals, including after-the-fact subaward approvals.
- Sponsored Projects Office (SPO), Subaward Team
- Processes subaward requests from UC Berkeley PIs.
- Conducts Subrecipient risk assessments, including participating in subaward risk assessment meetings, as needed.
- Compiles the subaward documents.
- Negotiates the subawards terms with the Subrecipients.
- Issues the fully-executed subawards.
- Collects the Subrecipient’s insurance certificates.
- Processes any amendments requested by the UC Berkeley PI.
- Accounts Payable Office
- Receives and pays subaward invoices, upon UC Berkeley PI approval (see the Accounts Payable website for more details).
- Contracts and Grants Accounting (CGA) Office
- Receives and pays Multiple Campus Award (MCA) invoices, upon UC Berkeley PI approval (see Subawards on the CGA website for more details).
The Subaward Process
Below are the basic subaward life-cycle stages, including the actions a UC Berkeley PI and Research Administrator should take at each stage.
Subaward Proposal Development
When developing a sponsored research proposal:
- Evaluate your Subrecipient’s role to determine that the outside organization will be functioning as a Subrecipient, and not as a supplier/vendor. See the Subrecipient vs. Supplier Wizard.
- Obtain a subaward proposal and subrecipient commitment form from the Subrecipient.
- Integrate the Subrecipient’s proposal information into UC Berkeley’s proposal, according to the sponsor’s requirements.
- Complete and collect any additional UC Berkeley required forms.
- Upload the Subrecipient’s documents and any other required forms into Phoebe.
See Subaward Proposal Development for details.
Subawards at Pre-Award/Just-in-Time Stage
When a sponsor indicates that they intend to fund UC Berkeley’s research:
- If you plan to issue Re-Grant Subawards, as a result of a Request-for-Proposal (RFP) process issued by UC Berkeley, contact subcontracts@berkeley.edu for guidance.
- Check with the Subrecipient to ensure they are still on track to participate in the research.
- Check with the Subrecipient PI to ensure they have not changed institutions.
- Check again to ensure your Subrecipient’s relationship to UC Berkeley is truly that of a Subrecipient, and not that of a supplier/vendor. See the Subrecipient vs. Supplier Wizard.
- Encourage the Subrecipient to register in the System for Award Management (SAM), if they have not done so already.
- Encourage the Subrecipient to get a Dun and Bradstreet (DUNS) number, if they have not done so already. (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.)
- Encourage the Subrecipient to establish a sponsor-compliant conflict of interest policy (if applicable), if they have not done so already.
- Obtain any just-in-time information or materials needed from the Subrecipient.
See Subaward Preaward or Just-in-Time for details.
Subaward Setup
Once SPO releases the Prime Award, with the Phoebe Award Summary (PAS):
- Review the information on Avoiding Subaward Delays, to check for issues that can be addressed up front.
- Talk with the Subrecipient PI about any needed changes to the Subrecipient’s budget and/or Statement of Work, based on what the Prime Award can support.
- Determine if the Subrecipient needs special financial considerations such as a working capital advance, payments in a foreign currency, or a fixed-price subaward.
- Submit a New Subaward Request directing SPO to issue the subaward.
- Provide feedback, as needed, to the SPO Subaward Specialist during the subaward preparation and negotiation process.
- After SPO issues the fully-executed subaward, establish a BearBuy Purchase Order for the Subaward, and provide the PO number to the Subrecipient.
See Subaward Setup for details.
Subaward Monitoring
After the subaward has become active:
- Review the subaward document, to understand its terms and conditions. Contact the Subaward Team (subcontracts@berkeley.edu) if you have any questions.
- Maintain an active collaboration with the Subrecipient PI.
- Monitor the Subrecipient’s work progress and technical performance.
- Monitor the Subrecipient’s spending in accordance with the approved budget.
- Plan for future subaward amendments.
- Alert SPO to any problems with the Subrecipient’s compliance with the subaward.
See Subaward Monitoring for details.
Subaward Amendment
To limit UC Berkeley’s financial risk, SPO usually obligates subaward funding in 12-month increments, through annual amendments.
Additionally, over the course of a subaward, other changes may be needed, such as to modify the Statement of Work or budget, to change PIs, to approve carryover, or to approve no-cost extensions.
When amending a subaward:
- Confirm with the Subrecipient that the changes are expected and acceptable.
- Submit a Subaward Amendment Request directing SPO to issue the amendment.
- Provide feedback, as needed, to the SPO Subaward Specialist during the amendment preparation and negotiation process
See Subaward Amendment for details.
Subaward Suspension or Early Termination
Occasionally, UC Berkeley will need to suspend or terminate a subaward. This can happen for many reasons, including suspension of the Prime Award, loss of sponsor funding, delays in the research progress, changes in Key Personnel, the Subrecipient’s early completion of their Statement of Work, or the Subrecipient’s inability to complete their Statement of Work.
If a subaward needs to be suspended or terminated early:
- Contact SPO at subcontracts@berkeley.edu for guidance on how to proceed with the suspension or termination.
- Submit a Subaward Amendment Request directing SPO to suspend or terminate the subaward.
- Provide feedback, as needed, to the SPO Subaward Specialist during the suspension or termination process.
See Subaward Suspension or Early Termination for details.
Subaward Closeout
After the Subrecipient completes their Statement of Work:
- Collect the Subrecipient’s final progress report and final invoice.
- Include information about the Subrecipient’s work products and results in UC Berkeley’s final report to the sponsor.
- Close out the BearBuy Purchase Order for the subaward.
See Subaward Closeout for details.
Other Guidance
Avoiding Delays in Subaward Processing
Many factors determine the length of time it takes to establish a subaward. Before requesting a subaward, learn about the most common delays and how to avoid them. See Avoiding Subaward Delays for guidance.
Subrecipient Commitment Form Guidance
All Subrecipients must provide UC Berkeley a commitment form. The type of commitment form needed depends on the type of Subrecipient. See Subrecipient Commitment Form Guidance for details.
Multiple Campus (MCA) Commitment Form | FDP Expanded Clearinghouse Participant Commitment Form | Subrecipient Commitment Form |
---|---|---|
Must be used by: Other UC Campuses; the UC Division of Agriculture and Natural Resources; the UC Office of the President | May only be used by: A Federal Demonstration Partnership (FDP) Expanded Clearinghouse Member | Must be used by: 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’s Strategic Partnership Office will provide a “Funds-in Memorandum Agreement Information Sheet” instead.
Subrecipient vs. Supplier Wizard
It is important to know whether an outside organization is acting as Subrecipient or a Supplier/Vendor. Organizations can serve in both capacities, depending on the Statement of Work. How an outside organization is characterized will affect which office handles the transaction as well as the proposal budget. For example, Berkeley’s Federal F&A rate is charged against all Supplier/Vendor costs, but is only applied to the first $25,000 of a Subrecipient’s costs. Budgeting an outside organization as a Subrecipient, when they should have been budgeted as a Supplier/Vendor can, therefore, have a serious impact on the project budget. To avoid this problem use the Subrecipient vs. Supplier Wizard at the proposal stage to help decide if an outside organization should be handled as a Subrecipient or as a Supplier/Vendor.
See the Subrecipient vs. Supplier Wizard for details.
Subaward Request
SPO accepts requests for new subawards and subaward amendments through Phoebe Search. SPO requires you to provide specific information and documents when requesting new subawards or subaward amendments. Refer to the Subaward Request instructions for detailed information on what is required and how to submit a request.
Subaward Forms and Other Resources
The SPO UC Berkeley Forms page provides all the standard forms needed for subawards. Always use the most current version of the forms, available on that page.
The following are other helpful resources relevant to subaward processing:
- Phoebe Search: Subaward Documents
- Federal Demonstration Partnership (FDP) Members
- Federal Demonstration Partnership (FDP) Expanded Clearinghouse Members
- System for Award Management (SAM)
- Federal Audit Clearinghouse
- Berkeley Controller’s Office: Vendoring
- Berkeley Contracts and Grants Accounting Office
- University of California, Office of the President, Contract and Grant Manual Chapter 16-400: Subawards
- University of California, Office of the President, Certificates of Insurance/Self Insurance: Policies on Subrecipient Insurance
- 2 CFR 200, Uniform Guidance (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards)
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.