A subrecipient is a third-party organization performing a portion of a UC Berkeley research project or program. The terms of the relationship are documented in a subaward (sub-grant/subcontract). Federal regulations for subrecipient monitoring are found in OMB Circular A-133 “Audits of States, Local Governments, and Non-Profit Organizations.”

Roles and Responsibilities:

1. Principal Investigators (PIs) have primary responsibility for the monitoring of 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.

2. 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.

Procedures:

1. The PI obtains the proposal from the prospective subawardee for participation in the project, and includes the proposal scope of work and budget in the prime proposal to the sponsor.

2. The PI determines when a subaward is to be issued. Extramural Funds Accounting provides financial procedures for subawards. A Request for New Subaward form is completed and forwarded to SPO. Forward with the Subaward Purchase Order (except for other UC campus subawards) and other documentation. SPO then prepares and issues the subaward.

3. 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. 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.

4. Closing Requirements: 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.