Subawards

The FDP Expanded Clearinghouse is a system that publishes online organizational profiles for use instead of using/asking for a subrecipient commitment form.  Pass-Through Entities (PTE) utilize this publicly-available information when issuing subawards and/or monitoring subrecipient organizations.

UCSB is part of this nationwide program to streamline the exchange of institutional information collected from potential subrecipient institutions. As a result of UCSB’s participation in this program, the documentation required of potential subrecipient institutions included in UCSB proposals (Outgoing Subawards) and of UCSB when acting as a subrecipient on another institution’s proposal (Incoming Subawards), have changed as described below.

Documentation Requirements for Subrecipients Included in UCSB Proposals (Outgoing Subawards)

As of March 1, 2021, institutions participating in this program are no longer required to complete the Subrecipient Commitment Form (UCSB/OR SK Form 100) when proposing to participate in a UCSB project as a subrecipient. Instead, participating institutions need only to provide project specific data (Subrecipient PI name, project period, total amount requested, cost share amount, authorized signature, compliances, etc.) via the Subrecipient Commitment Form - Short Form (UCSB/OR SK Form 100).  A list of participating program organizations can be found at the FDP Expanded Clearinghouse Program website.

Potential subrecipient institutions who are not part of the program are still required to complete the Subrecipient Commitment Form (UCSB/OR SK Form 100). 

Documentation Requirements when UCSB is a Subrecipient (Incoming Subawards)

When participating as a subrecipient on a proposal submitted by a fellow participating institution, the documentation expectations are reciprocal. Those preparing UCSB’s subrecipient proposal should expect to provide the PTE the same level of documentation we would expect if the roles were reversed.  Please note that institutions who are not part of the program may require additional institutional information and documentation from UCSB.

Please contact your SPO team should you have any questions.

Effective January 1, 2024, and per NIH Grants Policy Statement 15.2.1, all international
subrecipients must “provide access to copies of all lab notebooks, all data, and all
documentation that supports the research outcomes as described in the progress report, to
the primary recipient with a frequency of no less than once per year, in alignment with the
timing requirements for Research Performance Progress Report submission. Such access
may be entirely electronic.” Source: https://grants.nih.gov/grants/guide/notice-files/NOT-
OD-23-182.html
UCSB is required to amend all existing international subawards for NIH-funded projects; no
action is required on the part of the department or PI.

What this means: The UCSB PI for each NIH project with international subs is responsible
for ensuring and documenting that international subs provide access to such materials as
per progress report submission requirements as part of the subaward monitoring process,
and that such documentation is retained for three years beyond the grant’s final financial
report submission.