Subaward Best Practices for Principal Investigators

UCSF Projects with Outgoing Subawards

Proposal

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Use the Subcontractor or Purchase Agreement Matrix to appropriately confirm the project is an outgoing sub
Ensure the entity has the capacity to carryout their scope of work
Determine the budget type (fixed amount or cost reimbursable)
Work with your department and OSR staff support to ensure all required components are included

Proper budgeting at the proposal stage helps ensure adequate funding to carryout the scope of work

Award

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New Subaward

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Subaward Amendment

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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 and during award administration, 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 OSR staff support if the sponsor is a for-profit entity to ensure proper agreement classification

If ambiguous, consider the following questions.

If the answer is "yes" to any of the following questions, the agreement is likely a subaward:

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.

If the answer is "yes" to any of the following, the agreement is likley a vendor/service agreement:

Does the sub entity provide the goods or services to others for a fee?

If the agreement type is still unclear, consult with your OSR staff support

Budgeting

Budget Types

Cost Reimbursable

Reimbursement based on allowable incurred expenses up to an authorized amount

Fixed Amount

Reimbursement based on a defined firm fixed amount or deliverables

Commonly referred to as Fixed Price

Total award amount is negotiated up front

Examples: Installment, Milestone, Prepayment, Units of Service

Fixed Rate (NIH)

Reimbursement based on the negotiated costs per unit

Award amount may be unknown

Examples: Per patient cost in a Clinical Trial, per participant cost in a non-Clinical Trial Human Subjects Study

Pilot Projects and Unknown Subsites/Allocations

For proposals that include a to-be-determined allocation of subcontract funding (e.g., future competitive pilot/project/fellowship awards), the total of each subaward budget should be treated as Total Cost (with subrecipient indirect costs inclusive).

The PI should provide a best estimate of the number of subcontracts and OSR will budget F&A on the first $25,000 of each subaward planned. To avoid under budgeting F&A, best practice is to budget for the higher number of anticipated subcontracts within reason.

Indirect Costs

Sponsor guidelines determine the indirect cost policy to apply to the project.
When applying the MTDC indirect cost base, only include the first $25,000 of each subaward in the Prime indirect cost base.
Never include MCAs (subawards to other UC campuses) in the Prime (UCSF) indirect cost base.
When a subaward is supplemental funding (adding money that will expand/change its scope), include indirect costs in your budget as they may need to be reasssed when awarded.

Cost Sharing

Cost sharing by subrecipients on federal flow through subawards is discouraged and increases the subrecipient monitoring and required reporting.

The federal government and other sponsors define cost sharing as the portion of sponsored project costs not borne by the sponsor. There are three types of cost sharing:

Mandatory Committed
1. The sponsor requires cost sharing related to the award.
2. Effort and/or other costs are quantified in the proposal or award.
Voluntary Committed
1. The sponsor does not require cost sharing related to the award.
2. Effort and/or other costs are quantified in the proposal or award.
Voluntary Uncommitted
1. The sponsor does not require cost sharing related to the award.
2. Effort and/or other costs are not quantified in the proposal or award.

Special Considerations

Sponsor Prior Approval

Non-Profit Funded Projects

Carryforward/Carryover

Know Your Resources

Research Admin Glossary
Subcontractor or Purchase Agreement Matrix
Subaward Proposal Toolkit
Issue Subawards
Subaward Request Form: Short Form/Long Form/Instructions
Cost Sharing on Sponsored Awards
FAQs (OSR)
Outgoing Subawards Process and Monitoring (Controller's Office)
2.CFR.200.D Subreipient Monitoring
2.CFR.200.331 Subrecipient and contractor determinations

Office of Sponsored Research

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Subaward Best Practices for Principal Investigators

UCSF Projects with Outgoing Subawards

Determine Agreement Type Early

Budgeting

Special Considerations

Know Your Resources