Non-Profit and Federal Subawards

Subrecipient proposal elements must conform to the sponsor requirements for UCSF's prime proposal and in the required sponsor format. For foreign subrecipients, all documents required must be provided in English.

Each subrecipient must provide the following at the time of proposal:

1. Subrecipient Commitment Form if the subrecipient is not another UC campus.
   • If subrecipient is part the FDP Expanded Clearinghouse a Letter of Intent signed by an Authorized Institutional Official may be provided instead. 
2. Statement of Work (SOW): Describes the work to be conducted by the subrecipient. Define the deliverables including scientific reporting requirements and outline the time frame in which they are to be delivered. The SOW may also define all personnel and their responsibilities. It should be accurate and concise as to what, when, and if appropriate, how your organization will accomplish the work to be performed.
3. Budget and Budget Justification: Prepared in accordance with applicable sponsor guidelines and forms. Total costs will include the subrecipient’s direct costs for the project and indirect costs (if applicable). If the budget includes indirect costs, it must also include the calculation of the indirect costs.
4. Subrecipient's federally-negotiated F&A rate agreement, if applicable.
5. Multiple PD/PI NIH Assurance Form, (NIH, if applicable). 
   • This form is designed to comply with the requirements of NIH Notice NOT-OD-06-054. NIH requires that when multiple PD/PIs are proposed in an application, a written assurance be retained for all named PD/PIs and retained by the Prime Institution. If the subrecipient PI will be named as a PI/PD in UCSF’s proposal, this assurance must be signed and returned with the proposal packet and collected prior to submitting progress reports.
6. NIH Required Documents:
   • Subrecipient Letter of Support (per NOT-OD-23-182):
     • NIH expects recipients to ask potential subrecipients, at the application stage, to submit language in their letters of support indicating their awareness of these requirements and the subrecipient’s willingness to abide by all requirements should an award be issued. (NIH GPS 15.2)
     • For foreign subrecipients, a provision requiring the foreign subrecipient to provide access to copies of all lab notebooks, all data, and all documentation that supports the research outcomes as described in the progress report, to the primary recipient with a frequency of no less than once per year, in alignment with the timing requirements for Research Performance Progress Report submission. Such access may be entirely electronic. (NIH GPS 15.2.1)
     • Per NIH requirements, PI/Department or OSR Staff are expected to incorporate Language for Subrecipient Letter of Support into requests for application materials from subrecipients. If the sender is the PI/Department please copy your OSR Grants Specialist/Officer. The Research Security Program is available to assist PIs in accessing subrecipient data repositories and providing alternate options, such as UCSF Research Analysis Environment (RAE) for subrecipients who are unable to comply. Please reach out to [email protected]u early in the proposal process in case costs need to be included in your proposal budget. 
     • Guidance regarding NIH Research Performance Progress Reports (RPPR)
   • Biosketches (NIH) or CV, as applicable, for all key personnel
   • Facilities and Resources (NIH)
   • Equipment (NIH)

Effective August 1, 2012 for all Public Health Service (PHS)-funded subawards, the University is required to monitor subrecipient compliance with the PHS Financial Conflict of Interest regulations. PHS Agencies include: NIH, CDC, FDA, HRSA, AHRQ, IHS, SAMHSA, and ATSDR.  

The UCSF Subrecipient Commitment Form helps identify whether the subrecipient has a PHS compliant conflict of interest policy. For subrecipients that have certified compliance through the FDP Clearinghouse, the signed SCF will confirm the compliance. For subrecipients that do not have a PHS compliant conflict of interest policy, UCSF requires that the subrecipient adopt one before a Subaward can be issued. The resources below are provided to help with the adoption of a PHS compliant policy on conflict of interest. 

• Public Health Service FCOI regulations
• FAQs re: “Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought (42 CFR Park 50 Subpart F)
• Checklist for Policy Development related to the 2011 Revised Financial Conflict of Interest (FCOI) Regulation
• FDP “Model Financial Conflict of Interest Policy” (for potential adoption by Subrecipients who do not yet have an internal FCOI policy in places)