Outgoing Subawards

Checklist and Guidance

• Subaward Checklist - Departments/Principal Investigator
• Subaward or Contractor Checklist (Federal Demonstration Partnership (FDP))
• Subrecipient or Contractor Guidance

Forms

• Commitment Forms
  • FDP Expanded Clearinghouse Profile
  • Subrecipient Commitment Form - Use this form if the subrecipient is NOT included among the list of institutions participating in the FDP Clearinghouse
  • Multiple Campus Award (MCA) Commitment Form - Use this form for subawards to other UC Campuses
• Sole Source Justification Form (for Federal Contracts only)
• UC San Diego Single Audit and Mini Audit Questionnaire

Instructions

• Before budgeting for a subrecipient, first, determine if the collaborator you propose to work with is truly a subrecipient. For help in determining if your collaborator is a true subrecipient, consult Subrecipient or Contractor checklist for reference. Failure to categorize subrecipients and vendors/suppliers properly can have an adverse effect on the proposed budget and lead to delays in providing funds to these entities. If a determination is needed contact researchadmin@ucsd.edu.
• Use the PI/Department Checklist for Principal Investigators and Department Administrators as a useful guide.
• Please include the following as part of a PI’s proposal to the sponsor.
  • Commitment Form
    • Subrecipient Commitment Form– Use this form if the Subrecipient is not included in the list of institutions participating in the FDP Expanded Clearinghouse.

FDP Expanded Clearinghouse profile.

• Multiple Campus Award (MCA) Commitment Form – Use this form for Subawards to other UC Campuses.

• Subrecipient’s statement of work (SOW), including a clear and detailed description of the work to be performed, the proposed timelines, and deliverables.
• Subrecipient’s Budget and Budget Justification, including the subrecipient’s direct and indirect costs, calculated in accordance with sponsor guidelines using the subrecipient’s approved F&A and fringe benefit rates, and verifying any committed cost sharing.
• If the subrecipient does not have a current federally negotiated F&A rate in place they have the following options:
  • Use a de minimis F&A rate of 10% MTDC (or NIH foreign rate of 8%);
  • Negotiate a F&A rate with their Cognizant Federal Agency;
  • Elect not to charge F&A.
• If the proposal is for a Federal contract (not a grant or cooperative agreement):
  • Sole Source Justification-Completion of this form is mandatory when proposing subcontract(s) under a federal contract for sponsored activity and the subcontract is being issued without seeking multiple bids OR if subaward was not included in the original proposal submitted to the sponsor under a grant or cooperative agreement. See Uniform Guidance Section 200.324 or the Federal Acquisition Regulation 6.302-1 for additional guidance.
  • Any additional elements that may be required by UCSD’s sponsor for inclusion in the proposal.

Subrecipient proposal elements are expected to conform to the sponsor requirements for UCSD’s prime proposal and should be in the format required by the sponsor.

In rare instances, a PI may recognize the need for outside involvement in a project but is either unable to identify the best subrecipient by the time of proposal submission or is unable to acquire all of the required paperwork from that subrecipient. In these instances, proposals may be submitted with a subrecipient “To Be Named.” In these situations, PI is required to provide documentation of the basis for their subaward cost estimate for the work being performed. PIs will also be responsible for managing any budgetary shortfalls that may result from their inability to accurately predict a Subrecipient’s costs. Subrecipients should not be asked to reduce their F&A recovery or to otherwise cost-share because of UCSD’s failure to include appropriate costs in our proposal.

For International Subrecipients to an NIH Grant and Where UC San Diego is the Primary Funding Recipient Only:

• Effective January 1, 2024, PI ensures subrecipient access (electronic access permissible) to copies of all lab notebooks, all data, and all documentation associated with the research as described in the progress report to the primary funding recipient and in alignment with progress report submission requirements, but on no less than an annual basis per NIH GPS 15.2.1.
  
  
• PI should verify access and document the location of materials provided by the subrecipient, retaining documentation and access location for a period of three (3) years from the date of submission of the grant’s final financial report.

1. After submitting the KR request, it will be reviewed and placed into a queue for the next available Sponsored Projects Officer. Requests are handled in the order received. 
2. You will be CCed on the outgoing subaward agreement to the subrecipient.
3. After the subrecipient receives the agreement and/or required documents, a full review and return of a partially executed agreement can take on average 4-6 weeks (foreign subrecipients often take much longer).
4. The assigned Sponsored Projects Officer will serve as the Official Signatory for UC San Diego and will provide the fully executed agreement back to the Subrecipient with the KR Requisitioner as a CC on the email.

PI Responsibilities

The Principal Investigator is responsible for monitoring subrecipients so there is reasonable assurance that the subrecipient uses the award for authorized purposes, complies with laws, regulations, and the provisions of the agreement, invoices UC San Diego for allowable expenses in accordance with the agreement, and achieves its performance goals.

In the department the Principal Investigator with help from their Department Administrators is responsible for the:

• Invoices
• Subrecipient’s burn rate
• Subrecipient’s performance in accordance with the statement of work
• Complete and timely deliverables

One of the primary ways in which a Principal Investigator is required to monitor their subs is to review and approve each and every invoice prior to payment. All invoices must include:

• Current and Cumulative costs
• Subaward (KR) number
• Purchase Order number
• No Human or Animal charges unless prior approval granted
• Must have PI approval
• Final invoice must be marked as such

Each and every subaward is written with the right to reject an invoice.

For International Subrecipients to an NIH Grant and Where UC San Diego is the Primary Funding Recipient Only:
Effective January 1, 2024, PI ensures subrecipient access (electronic access permissible) to copies of all lab notebooks, all data, and all documentation associated with the research as described in the progress report to the primary funding recipient and in alignment with progress report submission requirements, but on no less than an annual basis per NIH GPS 15.2.1.

• PI should verify access and document the location of materials provided by the subrecipient, retaining documentation and access location for a period of three (3) years from the date of submission of the grant’s final financial report.

Sponsored Projects Office (SPO) Responsibilities

Subaward Team Manager or Officer:

• System of Award Management (SAM.gov)
• Visual Compliance - Foreign Entities
• Single Audit requirement review and management review
• Subrecipient Commitment form, if required
• Special Review (captures export control status, special invoicing requirements and deliverables, etc.)
• Risk Analysis
• Federal Funding Accountability and Transparency Act (“FFATA”) reporting

Subrecipients must submit a final invoice, clearly marked “Final”, to UC San Diego by the date that is required in the subaward agreement, typically no later than 60 days after the end of the Subrecipient’s period of performance.

A subaward is closed out when its period of performance comes to an end, regardless of whether UC San Diego’s research project is ending or continuing.

1. Remind subrecipients of needed reports well in advance of the deadline for such reports.
2. Obtain final technical reports from the subrecipients and retain a copy in the Principal Investigator’s project file.
3. Obtain other final reports from the subrecipients as required and retain a copy in the Principal Investigator’s project file. Other final reports might include property reports, patent reports, small disadvantaged business reports, and Assignment and Release documents.
4. Edit the KR record and change the Status to CLOSED- all unspent funds will be released back to the project. Do not reduce the financial obligations.

For more information visit the Closeouts page.