Subaward Best Practices: For OSR Staff

UCSF Projects with Outgoing Subawards

Proposal

 

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  • Use the Subcontractor or Purchase Agreement Matrix to appropriately confirm project is an outgoing sub
  • Include sufficient time to collect, review and revise subrecipient components
  • Ensure all required components are included
  • Retain supporting documents as needed
Award

 

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  • The department works with CGA to set-up the PeopleSoft/RAS award

Award must be in PeopleSoft/RAS before a subaward can be issued

New Subaward

 

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  • Initiate when PI/dept requests
  • Include required documents and information:
    1. Subrecipient Commitment Form, MCA or FDP LOI
    2. Scope of work
    3. Budget info
    4. Other docs, as applicable
Subaward Amendment

 

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  • Know if Sponsor Prior Approval is needed
  • Include the required documents and information: 
    1. Budget info, if applicable
    2. Provide revised documents only (do not submit unchanged (from previous sub)

Determine Agreement Type Early

Making the correct determination of whether an agreement is a subaward or vendor/service agreement at proposal stage will mitigate issues at the award stage, such as the need to rebudget due to incorrect indirect cost calculation. 

The nature of the project informs the agreement type: 

  • Budget and time savings are not appropriate justifications for determining if an agreement is a subaward. 

Review the Subcontractor or Purchase Agreement Matrix

Check with your team manager if the sponsor is a for-profit entity to ensure proper agreement classification

If ambiguous, ask the Principal Investigator: 

  • Will there be designated PI at the subsite?
  • Will the subsite be involved in programmatic decision making and/or design of the project?
  • Does the PI at the sub entity define their scope of work?
  • Is the PI at the subsite devoting measurable effort and requesting salary and benefits to achieve the scope of work?
  • Is the sub entity responsible for adhering to applicable prime sponsor's terms and conditions/policies?
  • Is the subsite the sponsor of the clinical trial protocol? Work requiring human/animal protocol approval does not always signify an outgoing sub.
  • Does the sub entity provide the goods or services to others for a fee?

If the correct agreement is still unclear, consult with your team manager, who may also consult with the Subcontracts team.

Special Considerations

Budget Types
  • For Cost Reimbursable budgets, provide the detailed budget, F&A rate and base information.
  • For Fixed Rate/Fixed Price budgets, provide the payment schedule and milestones.
Cost Sharing
  • Discourage cost sharing by the subrecipients on federal flow through subawards. 
  • Sub cost-sharing increases the sub monitoring and reporting required.
Sponsor Prior Approval

Sponsors often require prior approval from them for certain actions. Read the sponsor guidelines, policies and award terms & conditions. 

Non-Profit Funded Projects
  • Budget periods often do not exist for non-profit funded agreements and policies governing are different. 
  • We have more flexibility to manage and may be able to issue the sub for longer than one year.
Carryforward/Carryover

Non-federal sponsors and awards are often silent (do not address carryforward). In these cases, the PI and department determine how to manage carryforward in subawards. 

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