Contracts & Grants: Subrecipients

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Subrecipients

What is a Subrecipient and Contractor?

Subrecipients and Contractors are entities such as other campuses or collaborators that participate in carrying out a portion of the project and receive funding drawn from the prime award. These relationships can qualify as either a Subrecipient (subaward) or a Contractor (vendor/consultant) and will affect differences in the terms and conditions of the award. Questions should be directed to the Office of Contracts & Grants (OCG@ucanr.edu) while developing the proposal to determine which relationship is appropriate.

Determining a…..

Contractor (Vendor/Consultant)	Subrecipient (Subaward)
Does the entity provide the goods or services within normal business operations?	Will the entity’s performance be measured against whether the objectives of the project are met?
Does the entity provides similar goods or services to many different purchasers?	Does the entity have responsibility for programmatic decision making?
Does the entity operate in a competitive environment?	Does the entity have responsibility for adherence to applicable program compliance requirements?
The entity will NOT be involved in the programmatic decision- making of the project?	Does the entity have the right to publish project results or serve as a co-author?
The entity will NOT be subject to applicable program compliance requirements?	Does the entity have the option to develop patentable technology?

If yes to the questions above, this activity should be classified as a vendor or consultant.	If yes to the questions above, this activity should be classified as a Subaward.

What are the differences that will impact my budget preparation?

Vendor/Consultant	Subaward
Vendors and consultants should be categorized in the Supplies & Expenses category of the proposal budget.	Subawards should be categorized as a separate line item under Miscellaneous Costs in the Proposal Budget.
Indirect costs will be assessed on the full amount of line item.	Only the first $25,000 of a subaward expense should be included in the base when calculating Indirect Costs when using our federally negotiated rate. Any subaward amounts in excess of $25,000 will not be subject to indirects. See Exceptions to this below**

**Exceptions:

1) Using an indirect cost rate other than our federally negotiated rate. Some sponsor policies may use a Total Direct Cost or Total Cost base to calculate the indirect costs.

2) For subawards to other UC Campuses the entire amount of the subaward is excluded from the base when calculating indirect costs. However, the F&A rate of the participating campus should be included as part of their budget for that campus.

What items do I need to include with my proposal?

Vendor/Consultant	Subaward
Include in budget justification	Letter of authorization from collaborating Institution
Bid form, if applicable	Description of scope of work
Letter of support, if applicable	Budget
Any other required documents or approvals required by the sponsor	Subrecipient Commitment Form
	Any other required documents or approvals required by the sponsor

The OCG initiates and issues all subawards for extramurally funded projects on behalf of the University.

UC Davis Business Contracts initiates and issues all vendor and consultant contracts on behalf of ANR.

**Changes with the new Uniform Guidance** As allowed in the Uniform Guidance ANR will delay the implementation of the Procurement changes through 12/26/2015. Be sure to check with your campus procurement department.

Micro purchases: Acquisition of supplies or services if the aggregate dollar amount including tax and shipping does not exceed $3,000 (or $2,000 for David-Bacon Act)
Small Purchases: Under $150,000 (or $100,000 if State law prevails. Check with your campus Procurement Department.) Purchases using this selection should only be used when the product or services are commercial in nature; that is, readily available (sold on the commercial market with established market pricing.) Quotes will need to be obtained from two or more suppliers.
Sealed bids (formal advertising), competitive proposals and noncompetitive proposals (sole source): Detailed instructions associated with these three processes. Discuss with your campus Procurement Department.

Policies:

UCOP Contract and Grant Manual Chapter 8-516

Uniform Guidance (2 CFR 200)