What is a Subaward? An agreement that transfers a portion of the research or substantive effort of the prime award to another institution or organization. Subs are written under the authority of a prime award and are consistent with the terms and conditions of the prime award. A formal binding legal agreement between the University of California, Los Angeles (“UCLA”) and a non-UCLA entity in which: –A defined portion of the UCLA work statement’s intellectually significant activity is assigned to another entity (“the subrecipient”) to fulfill; –Work is generally performed by the subrecipient’s personnel using their resources, usually at their site; –The subrecipient takes full responsibility, including intellectual leadership, for the portion of UCLA’s work statement that they will undertake; –The award terms and conditions UCLA has accepted from our funding agency are “flowed down” to the subrecipient, who must also agree to comply with them (e.g., audit requirements, restrictions on rebudgeting, human and animal subjects approvals, conflict of interest, clean air and water, etc.).
Common Terms Prime –Usually refers to the Sponsoring Agency of the contract, grant or cooperative agreement awarded to UCLA. Subrecipient –The legal entity to whom a subaward or subcontract is made and who is accountable to UCLA for the use of funds provided. A subrecipient has its own PI who will carry out a substantive, scholarly portion of the scope of work described in the proposal. –aka: Subawardee
Different Types of Subawards 1) Subcontract –When UCLA receives a CONTRACT, and then transfers a portion of the research or substantive effort of that contract to another institution. –UCLA Purchasing Office is responsible for issuing and monitoring subcontracts. –BruinBuy order class: S –Object Codes: 7310, 7300
Different Types of Subawards 2) Subgrant –When UCLA receives a GRANT or COOPERATIVE AGREEMENT, and then transfers a portion of the research or substantive effort of that grant or cooperative agreement to another institution. –At UCLA, it is referred to as a “subaward.” –Handled, in majority, by OCGA. –BruinBuy order class: G –Object codes: 7310, 7300
Direct Cost Ceiling UCLA’s Total Direct Cost = –UCLA’s Direct Cost, plus (+) –Subaward’s Direct Cost, plus (+) –Subaward’s F&A This is also what your OCGA analyst and/or DRA’s signature authority is based on. Example: DRA’s cannot sign off on any proposal where UCLA’s Total Direct Cost exceeds $500,000 in any given budget period. NIH Notice NOT-OD-04-040: If, in the PA or RFA, the NIH indicates there is a Direct Cost Ceiling limitation, the NIH only counts UCLA’s Direct Cost + Subaward’s Direct Cost towards the ceiling limit.NOT-OD-04-040 –This is to encourage collaborations outside of the PI’s own institution, and not penalize a PI by counting the subaward’s F&A towards the ceiling.
Direct Cost Definitions UCLA’s Total Direct Cost = UCLA’s DC + Sub’s DC + Sub’s F&A NIH Direct Cost Ceiling = UCLA’s DC + Sub’s DC
Scenario UCLA PI wants $100,000 to use towards his own lab. Subaward Direct Cost is $50,000, and F&A is $32,000 1. What is UCLA’s Total Direct Cost? 2. Assuming the $100,000 for the UCLA PI is for salary & supplies only, what is UCLA’s MTDC base? – What if the sub is to another UC? 3. What amount is counted towards the NIH’s Direct Cost Ceiling? 4. What amount is counted towards an SO’s signature authority?
Subawards: Proposal Preparation UCLA as prime grant recipient issuing subaward to an outside institution or other UC
Documentation Required Subaward/Subrecipient Forms Checklist –Email checklist to subrecipient to ensure correct versions of all required forms are obtained. –Subrecipient Commitment Form required. PHS 398 Face Page is no longer accepted in its place.Subrecipient Commitment Form PHS 398 Face Page –All forms must be completed/received PRIOR to proposal submission.
Subawards in S2S/Cayuse For Both Detailed (RR Budget) and Modular Budgets: –Always allow S2S to auto-calculate UCLA F&A. –Only overwrite the auto-calculated figures if you are 100% sure you are correct. HINT: S2S/Cayuse is always right! –Subawards to other UCs are entirely exempt from UCLA F&A calculations.
Subawards in S2S/Cayuse Do NOT forget to incorporate the following information from your subawards into your proposal: –Subaward’s Performance Sites. –Subaward’s Facilities and Other Resources information. –Subaward’s Equipment. –Full Professional Profiles & Biosketchs for all subaward Key Personnel. –Under Research Plan section: Consortium/Contractual Arrangements. See S2S Subaward Review for requirements for this section.S2S Subaward Review Letter of Support from subaward PI.
Subawards in S2S/Cayuse Modular Budgets –Under the RR Subaward Budget Attachment, only need to complete a Worksheet Row for each subaward. Manually enter the subaward’s direct cost and F&A amounts provided to you by the subawardee. Do NOT mark the checkbox next to the RR Subaward Budget Attachment, as the Worksheet Row data should NOT be submitted to the agency. –Under the PHS 398 Modular Budget, include the Consortium Justification. See S2S Subaward Review for items required to be included in the Consortium Justification.S2S Subaward Review
Subawards in S2S/Cayuse Detailed Budgets (RR Budget) –Institutional ProfilesInstitutional Profiles Required for proposals with detailed budgets. Allow at least a few days for the subawardee to complete the request form, and an additional few days for S2S Admin to set up the Institutional Profile in S2S/Cayuse. –In the RR Subaward Budget Attachment you will need to incorporate a complete detailed budget for each of your subawards (see next slide for 4 methods). Be sure to mark the checkbox next to the RR Subaward Budget Attachment, as the detailed budget must be included in the proposal to the agency.
Subawards in S2S/Cayuse S2S/Cayuse –4 ways to enter a detailed subaward into Cayuse: 1.Uploading the Grants.gov Adobe PDF subaward proposal packet, provided by the subawardd. 2.Importing another Institution’s Cayuse/S2S proposal. 3.Subawards.com - a free service that simplifies collaboration between research institutions preparing federal grant proposals together.Subawards.com 4.UCLA Fund Manager manually enters data into Cayuse using the forms provided by the subawardee.
Subawards: Proposal Preparation UCLA as the subawardee
What about when UCLA is the subawardee? Work with your contact for the prime institution. They may have their own set of requirements. For NIH grants, more than likely, you will be required to complete the Grants.gov SF424 Adobe PDF subaward packet. –Download directly from the Grants.gov RFA/PA packet. –Available on the DOM ORA Website, under Pre-Award Forms – Subaward SF424 Adobe Budget. Pre-Award Forms – Subaward SF424 Adobe Budget
What about when UCLA is the subawardee? Create a mini-proposal which usually includes at least the following documents: –Face Page/Prime’s subrecipient commitment form (aka statement of intent). –Performance Site location information. –BioSketches & Key Person Profiles for all UCLA Key Personnel. –Resources & Equipment files for UCLA PI. –Statement of Work. –Letter of Support. –Budget (usually the SF 424 Subaward Packet) and Budget Justification. Once Face Page/Subrecipient commitment form is signed by OCGA, send the mini proposal directly to your contact at the primary institution. They will then incorporate your documents into their proposal that gets submitted to the agency.
Post-Award Subaward Process See “Subaward Set Up” and “Subaward BruinBuy Requisition Setup” chapters in the Post-Award section of the Fund Manager’s ManualSubaward Set UpSubaward BruinBuy Requisition Setup
Subaward Monitoring Ask Subawardee’s Fund Manager for periodic detailed financial reports to reconcile applicability of expenses. Invoices received by the subawardee for payment MUST be approved by the PI prior to processing via Accounts Payable. –PI signs the actual invoice as indication of approval. PI is responsible for assuring work has been completed by the subawardee PRIOR to approving invoices. FINAL invoice should always have “FINAL” on them in order for EFM to close fund. In order to make any changes to the subaward, a Checklist must be completed and signed by PI. Checklist
Resources OCGA’s Subaward Initiation & Management WebsiteSubaward Initiation & Management Website CHR’s Class: Outgoing Subawards Initiation & ManagementOutgoing Subawards Initiation & Management –Planning for a subaward vs. a consultant vs. a vendor –Subawards in proposals: documentation needed from subrecipients; how to list the subaward in UCLA's budget; how to represent F&A costs. –Issuing and monitoring subawards-the role of OCGA, EFM, the Department/PI, Purchasing and Accounts Payable –How to process a PAC requisition to request issuance of a PO and subaward, including utilization of the correct object codes for appropriation of F&A costs. Purchasing’s UCLA Subaward documentsUCLA Subaward DOM ORA’s Subaward Set-UpSubaward Set-Up DOM ORA’s Subaward Forms ChecklistSubaward Forms Checklist DOM ORA’s S2S Subaward ReviewS2S Subaward Review DOM ORA’s S2S Subaward Attachment RequirementsS2S Subaward Attachment Requirements DOM ORA’s Subaward BruinBuy Requisition SetupSubaward BruinBuy Requisition Setup