Outgoing Subawards Process and Monitoring
A subaward is a formal legal agreement between the Regents of the University of California on behalf of its San Francisco campus (UCSF) and another organization (subrecipient). An outgoing subaward is used when a substantive portion of the programmatic work outlined in a UCSF proposal is conducted at another organization. The subrecipient takes full responsibility for adhering to the terms and conditions of the subaward including those flowed down from UCSF’s sponsor under the Prime award. UCSF’s Principal Investigator (PI) and his/her associated administering department are responsible for the conduct of the subrecipient’s work. PIs and departments should carefully read and follow regulations related to subawards in order to remain in compliance.
Subawards in Preaward and Proposal Development
Information about subawards including templates and samples of the documents required by Research Management Services (RMS) at the time of proposal are available on the Office of Sponsored Research (OSR) website. Also available on the OSR website is the Subcontractor or Purchase Agreement Matrix. This matrix of guidelines is provided to help researchers and administrators determine whether third-party work is collaborative research or the procurement of goods and services so that proposals can be properly prepared and funds expended in accordance with terms and conditions, policies, and applicable regulations and laws.
Establishing a Subaward
- UCSF receives an award with approval for a subawarded scope of work.
- A Subaward Request Form is initiated for each proposed subrecipient. This form and instructions are available on the OSR website. The RMS Research Support Coordinator (RSC) works with the PI/Department to collect the required information and documents necessary to complete the subaward request. The Subaward Request Form instructions can help ensure that the request is complete and all required documents are attached in order to establish a subaward.
- Once the subaward request packet is complete and endorsed by the PI, the request is submitted by the RSC to the OSR Subcontracts Team mailbox [email protected]. The Subcontracts Team reviews the packet to ensure completeness and accuracy and conducts a compliance review. If the request is actionable, the Subcontract Associate enters the subaward data in the Research Administration System (RAS). RAS assigns an auto-generated tracking ID.
- OSR’s Subcontract Officer receives the packet from the Subcontract Associate and conducts further compliance actions, if required, reviews the packet and the UCSF prime award to draft the appropriate subaward agreement, sends the agreement to the recipient institution and handles any negotiation required to execute the award. When necessary, the OSR Subcontract Officer will confer with the PI/Project Director on any programmatic issues.
- The OSR Subcontract Officer or the Subcontract Manager signs the agreement on behalf of UCSF. The final executed agreement is returned to the recipient institution (via email) with a copy to the PI and the UCSF contact noted on the subaward request form. OSR adds information into RAS and uploads a PDF of the signed contract.
- If a subrecipient will be contributing to the coverage of a cost share commitment, complete or update the Cost Sharing Budget Template with the Subaward Cost Sharing section completed and submit to CGA Compliance.
Facilities and Administrative Costs (F&A)
F&A is assessed on the first $25,000 of each subaward for a project period. When the renewal comes around, the F&A is assessed again, on the first $25,000 of each subaward. However, it is not assessed beyond the first $25,000 on continuation proposals.
UCSF claims no F&A on subawards going to sister UC campuses – officially known as Multiple Campus Agreements (MCA) - because all UC campuses are considered one entity, "The Regents of the University of California." This does not mean the other campuses cannot request F&A on their proposals, but rather that UCSF does not assess F&A on any MCA going to another UC campus, regardless of amount.
Subaward Invoice Standards
A subaward invoice should include basic information such as the subrecipient name, address, contact information, payment information, UCSF subcontract number, period covered and date of the invoice. To meet compliance requirements, subaward invoices should also include the following.
- Enough expense detail to ensure that the invoice aligns with the budget, allowable costs and matches scientific progress
- Indirect cost rate clearly indicated an itemized separate from direct cost
- Indicate exclusions to IDC recovery is used that match executed subaward agreement
- Working capital advance reconciliation where applicable
- For federal awards, PI approval and the required certification should be included on each invoice
By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (U.S. Code Title 18, Section 1001 and Title 31, Sections 3729-3730 and 3801-3812).
Process to Pay Subaward Invoices
- Campus department obtains signature approval through DocuSign.
- Department downloads approved invoice from DocuSign.
- Department emails approved invoice to Supply Chain Management (SCM) Accounts Payable Subcontract Email.
- SCM Accounts Payable processes and pays invoice.
For additional details, see Subcontract Invoice Approval on the Supply Chain Management website.
Department and Principal Investigator Responsibilities
- Determine the appropriate classification of costs at the time of proposal as a subaward or purchase agreement.
- Monitor subrecipient to assure that invoices and progress reports are submitted in a timely manner.
- Review invoices received from the subrecipient for allocability, allowability and reasonableness of costs and that charges are within the period of performance of the prime award.
- Department reviewers should coordinate closely with the PI in order to determine that costs are appropriate for the subagreement.
- Monitor subrecipient’s progress and determine whether payments are in alignment with progress and terms of the subaward.
- Subrecipient invoices provide enough detail to determine how awarded funds are being used.
- Question costs which differ materially from the approved budget or which appear unusual or unallowable, and withhold payment until a satisfactory explanation is received and documented.
- Assure that final invoices are identified as such.
- Approve invoices and submit to Accounts Payable for processing.
- If the subrecipient is contributing to any mandatory cost sharing commitments, the Department should review the invoice for indications that the subrecipient is meeting commitments and has certified that all expenses are appropriate.
- Review RAS reports for all subawards.
- Assure that reports (including scientific and progress reports) and other material requested from the subrecipients have been collected and reviewed.
- Retain all reports after the UCSF Award final expenditure report submission for the same period of time as required for documentation of the prime award.
- Assure that project closeout requirements required by federal award terms are completed.
- Office of Sponsored Research Subcontracts Team email: [email protected]
- Accounts Payable Subcontract Inquiries:
- Contracts & Grants Accounting Compliance: [email protected]
- Contracts & Grants Accounting Customer Service Desk: [email protected]