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Subawards

Researchers at UC Davis often find that their research and other projects can be enhanced by partnering with other institutions on extramurally funded projects. When the partnering institution provides a significant portion of the programmatic effort and exercises independent responsibility for programmatic decisions, this partnership usually takes the form of a subaward.

Subawards

If you know when you prepare your proposal that the project will have a subaward, you should include the subaward information in your proposal package. If you determine that you will be partnering with another institution after your award has been completed, you should contact Sponsored Programs for assistance. Sponsored Programs will help you review your award agreement for information about adding a subawardee to the project.

The potential subawardee must provide a concurrence letter from the institution receiving the subaward, an institutionally endorsed proposal (complete with scope of work and budget) and in some cases, a subrecipient monitoring form. Sponsored Programs will develop a subaward agreement with the partnering institution, and will negotiate terms and conditions as necessary. To help you remember what you will need to get from a subawardee, we have created a Quick Guide to Subawards for your use.

Subrecipient Monitoring

UC Davis is responsible for ensuring that extramural funding received by the University is managed and spent according to the terms and conditions of the sponsor, as well as the policies and regulations of the University. This responsibility extends to our work with partnering institutions. Sponsored Programs works with Extramural Funds Accounting to fulfill this responsibility by using subrecipient monitoring forms to collect information about subrecipient institutions as well as the specific projects they will be working on with UC Davis.

There are two major types of subrecipient monitoring forms: annual certifications and proposal-specific commitments.

Annual Certification

Annual certification subrecipient monitoring forms ask for information that helps UC Davis determine the institution’s financial viability. This includes assessing whether the institution has the mechanisms in place to manage the funding they receive, as well as whether there have been any past audit issues. This assists UC Davis in fulfilling its fiduciary responsibility. You shouldn’t be immediately concerned if the institution receiving the subaward does not already have in place all of the mechanisms needed to manage all types of funding. Not all items on the subrecipient monitoring forms are applicable to all institutions or situations, so Sponsored Programs will work with both the PI and the subawardee to determine whether any financial viability issues need to be resolved.

If the institution is subject to A-133 audits, they will be asked to provide information about the institution’s most recent A-133 audit (for information about A-133 audits, visit the OMB's A-133 website). If the institution is not subject to A-133 audits, they are asked to complete a financial questionnaire.

When a subaward is listed on a sponsored project, Sponsored Programs will identify whether there is already a current annual certification on file with our office, or whether one is needed. You will not need to determine this yourself.

Proposal-Specific Commitments

When UC Davis provides a subaward to an institution that is not a part of the Federal Demonstration Partnership (FDP), the subawardee is required to complete a proposal-specific commitment form. This provides UC Davis with information needed to make compliance certifications to the sponsor, as well as identifying any areas where special attention must be paid. This form must be received by Sponsored Programs before a subaward can be given to a non-FDP institution. To determine whether the institution you are working with is a member of the FDP, you can view the list of FDP Member Institutions. To expedite award processing time, it is suggested that PI’s working with non-FDP institutions request the Proposal-Specific Commitment Form when other subrecipient information is requested (e.g., scope of work and budget).

Federal Reporting

If your project is providing a subaward totaling $25,000 or more of Federal funds, the subaward may be required to be reported under the Federal Funding Accountability and Transparency Act. The OR-Sponsored Programs office will use the data elements from the Subrecipient Monitoring forms to complete this reporting.

If you have received funding under the American Recovery and Reinvestment Act (ARRA), and are planning to have a new subaward using this funding, please contact Sponsored Programs for assistance with federally required ARRA subrecipient monitoring.

Mandatory PHS Financial Conflict of Interest (FCOI) Requirements

Each subrecipient must complete a Subrecipient Commitment Form which can be found on the Forms page.

If a subrecipient indicates on question #9 of the Subrecipient Commitment Form that they "have a PHS compliant Financial Conflict of Interest Policy in place and that each investigator has completed the required PHS FCOI training", no additional paperwork is required.  The subrecipient will be expected to rely on their own policy and report FCOIs to UC Davis in accordance with the PHS requirements.

If a subrecipient indicates on question #9 of the Subrecipient Commitment Form that they "will abide by UC Davis's Individual Conflicts of Interest Involving Research Policy", they must complete the PHS Financial Disclosure Form for Investigators from subrecipient entities that do not have a PHS-compliant conflict of interest policy in effect at time of PHS award application which can be found on the Forms page.

Working with International Subrecipients and Small Organizations

Please note that many international subreceipients or small organizations may not be familiar with obtaining a DUNS number and registering in the federal System for Award Management (SAM). As such if you are both receiving federal funding and working with an international subrecipient, we recommend informing the subrecipient of the potential need to obtain a DUNS and register in the federal System for Award Management (SAM) at the time of proposal. The DUNS number request and SAM registration can take about a month to be processed, and the OR-Sponsored Programs office is prohibited by Federal law from releasing subaward funding until these two pieces of information are provided. We would like to avoid any unnecessary delays at time of award.

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