Who is responsible for monitoring a subrecipient?

Principal Investigators (PIs) have the primary responsibility for monitoring subrecipients to ensure compliance with federal regulations and with the terms of both the prime award and the subaward.

PIs are responsible for ensuring that subaward costs are reasonable and allowable. PIs are also responsible for the receipt and review of technical performance reports or other deliverables and the review of expenses vs. budget. There may be additional sponsor-specific or program-specific requirements that mandate collection and documentation of other kinds of assurances (e.g., on laboratory animals, human subjects, biohazards, etc.) during the course of a project. Extramural Funds Accounting provides guidance on subrecipient monitoring after an award is made.

The Sponsored Projects Office (SPO) has responsibility for ensuring that subaward agreements contain appropriate federal and other applicable regulations consistent with sound business practices and for collection of subrecipient federal audits, if necessary. SPO has been delegated the authority to prepare and negotiate all subawards for collaborative research.

Why is a Subrecipient Commitment Form needed before an award is issued?

The federal government requires UC Berkeley to document subawardee compliance with regulations such as those governing research with human or animal subjects, conflict of interest disclosures, and OMB Circular A-133. The Sponsored Projects Office is offering the Subrecipient Commitment Form as a new tool for campus departments and subrecipients to understand what is needed to prepare and issue subawards.

Having needed data at proposal submission stage puts the institution in compliance with federal regulations and expedites the issuance of subawards. Having material submitted at proposal stage will allow subawards to be processed and issued more quickly. Having the information at award stage reduces the time to independently research and verify the information included on the form.

The Subrecipient Commitment Form is to be completed and signed by an authorized institutional representative of the subawardee and provided at proposal stage with other proposal documents.

The form also is to be used for awards that did not include the form at proposal stage. When UC Berkeley investigators are requesting subawards at award stage, the Subrecipient Commitment Form must be completed and signed at the time of award by an authorized institutional representative of the subawardee.

The University of California, Berkeley requires that the following documents be included in order for a named subrecipient to be included as part of a principal investigator’s proposal to the sponsor. Proposals will not be endorsed by institutional officials 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.
• A Subrecipient Commitment Form, completed and signed by the subrecipient’s institutional official.

If the prime is a contract,

• 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.

Subrecipient proposal elements are expected to conform to the sponsor requirements for UC Berkeley’s prime proposal. PIs are responsible for ensuring that they request all materials from their subrecipients in the correct format. 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.

(1) PI assesses subrecipients

• Verify that this is a subaward as opposed to a purchasing action processed by the Business Contracts Office.
• For contracts, include a Fair and Reasonable Cost Analysis and Sole Source Justification: Subawards Under Contracts.
• If PI has financial interest in the subrecipient, PI must complete Form 700-U Statement of Economic Interests and Form 700-UA Addendum to Statement of Economic Interests.

(2) PI prepares a proposal including a subaward

• Incorporate subrecipient’s proposal and SOW into UCB’s for consideration as one proposal.
• Include the subrecipient’s budget as a line item in UCB’s budget.
• Include other subrecipient documents (e.g., budget forms, biosketches, other support) as required by sponsor.
• Forward completed UCB proposal to Sponsored Projects Office for review, including signed Subrecipient Commitment Form. For contracts, include a Fair and Reasonable Cost Analysis and Sole Source Justification: Subawards Under Contracts.

(3) Sponsored Projects processes the proposal

• Verifies that this is a subaward as opposed to a purchasing action processed by the Business Contracts Office.
• Verifies that all required subrecipient documentation is present.
• Endorses proposal and submits to sponsor for consideration.
• Retains subrecipient documents for use at award stage.

The PI determines when a subaward is to be issued. The PI must verify that this is a subaward, not a purchasing action processed by the Business Contracts Office.

A Request for New Subaward form is completed by the PI and forwarded to SPO: subcontracts@berkeley.edu. If the PI has financial interest in the subrecipient, the PI must complete Form 700-U Statement of Economic Interests and Form 700-UA Addendum to Statement of Economic Interests, unless already submitted at the proposal stage. Subawardees not subject to an A-133 audit will be required to complete a Mini-Audit Questionnaire. The PI also forwards the Subaward Purchase Order (except for other UC campus subawards) and other documentation.

SPO then:

• Verifies that this is a subaward as opposed to a purchasing action processed by the Business Contracts Office.
• Verifies that all required subrecipient documentation is present.
• Prepares and negotiates subaward.
• Issues subaward.

The PI determines when a subaward is to be amended. Common reasons for amending a subaward include providing additional funding, extending the period of performance, or modifying the reporting schedule. It is important to note that some changes, such as scope of work changes, change in the subaward recipient's principal investigator or transferring the subaward from one recipient to another, may require the prior approval of the prime sponsor. Requisite changes are made in BFS by the PI. The amount of funding and duration of the agreement are noted on a Request to Amend Existing Subaward form, and the form is forwarded to SPO. SPO then amends the subaward.

The subaward recipient is required to submit a final technical report and final invoice at completion of the agreement. Additional reports may be necessary, as required by the prime sponsor agreement. These may include a final inventory of property or an invention report. Principal Investigators should not approve final payment until all reports have been received.

Principal Investigators, assisted by department administrators, are responsible for conducting timely and appropriate financial and programmatic reviews of the technical information and invoices submitted by subaward recipients. SPO and Extramural Funds Accounting can assist with securing information and invoices from subaward recipients who have failed to meet their obligations under their respective subawards. However, timely notification to SPO and Extramural Funds Accounting is essential to help ensure a successful and collegial resolution to such issues.

If you have additional questions about establishing a subaward, please contact Jennifer Nadeau at jancal01@berkeley.edu.

For more information, Extramural Funds Accounting provides financial procedures for subawards.