Subaward Definition

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.).

Examples of Procurement Actions

• Commercially available supplies and expendable materials
• Expert consulting ( consulting firm or independent individual)
• Non-University labor or services
• Equipment or components parts for fabricated equipment of fabricated equipment which will be delivered to and used by the sponsor or other entity designated by the sponsor

Decision Matrix

A subaward may be appropriate if you can answer yes to any of the following:

• Does the entity’s statement of work represent an intellectually significant portion of the programmatic effort of the overall project?
• Does the entity have responsibility for programmatic decision-making?
• Is there an identified principal investigator for the entity? Is he or she a co-investigator on the primary proposal?
• Could the entity’s work result in intellectual property developed?
• Are publications anticipated from the entity? Will individuals at the entity be co-authors on articles?
• Will the entity need animal and/or human subject approval for its portion of the work?
• Is the entity providing cost sharing or matching funds?

A procurement action may be appropriate when the entity:

• Is to perform a series of repetitive tests or activities requiring little or no discretionary judgment (e.g. Entity performs a test on data we provide to them and gives us the results to analyze.).
• Provides the goods and services within its normal business operations (e.g. Entity regularly sells the goods or services as a part of their routine business operations, usually at a fixed price or rate (e.g., pipettes, tanks of hydrogen, etc.)).
• Provides similar goods and services to many different purchasers.
• Operates in a competitive environment.
• Is not subject to the compliance requirements of the prime sponsor.

Not all of the characteristics need to be present to determine whether an entity is a vendor or subrecipient. If you are having trouble making a determination, contact your Contract & Grant Officer or Grant Analyst.