September 30, 2008

Redesigning the Campus Research Subaward Process

Background: Business Process Analysis

The Research Administration and Compliance Office (RAC) was one of several campus groups participating in the business process analysis workshop recently offered by the campus Center for Organization and Workforce Effectiveness (http://administration.berkeley.edu/forms/newsletter/spring-08-about.htm#bpa). The workshop, held from March to May 2008, provided coaching and training for teams actively engaged in improving real campus business processes.

The workshop provided participants with tools and methods to help analyze processes, identify areas for improvement, redesign processes to incorporate improvement ideas, and lay out a framework for ongoing review and improvement of processes.

Assistant Vice Chancellor for Research Marcia Smith selected a team of RAC and Sponsored Projects Office (SPO) staff to participate in the workshop and focus on the research subaward business process. The issuing of subawards under research grants and contracts is an operational challenge for most research institutions and is a process that is growing in volume and complexity.

The RAC business process analysis team was trained to use a set of tools and various approaches to business process redesign, and they applied that training to redesigning the subaward process. As a result of the team's effort, several improvements have already been made to the subaward process and more are on the way.

Subaward Process Improvement: Coeus Data for PIs

One major change is that more complete and current data on subawards and subawardee organizations is now being collected in Berkeley Coeus and can be shared with principal investigators and staff. Based on the new subaward information carried in Coeus, the Notice of Award sent to PIs and administrators now includes more detailed information, including the status of each subaward and guidance for the PI and department about what the status means for them. In addition, Berkeley Coeus Web will soon have a new research subaward report so that PIs and department staff can track subaward status online. The following statuses for subawards have been defined and implemented.

1. Pending: The subaward is known by SPO but a Subaward Request Form has not been submitted by the department.
2. In process: The Subaward Request Form has been received by SPO, and the subaward is being prepared for signature and transmission to the subawardee.
3. Amendment in process: The Subaward Amendment Request Form has been received by SPO and the amendment is in process.
4. Awaiting subawardee response: The subaward/amendment has been sent to the subawardee, but has not yet been returned fully signed.
5. Active: The subaward is fully executed and distributed.
6. Inactive: The subaward’s final expiration date has passed.

In addition to providing more information to PIs and staff, tracking and managing subaward data in Coeus is key to complying with federal regulations, including the Federal Funding Accountability and Transparency Act (FFATA), which will require the campus to provide data about subawards to the federal government for public access (http://www.usaspending.gov/).

Subaward Process Improvement: Subrecipient Commitment Form

SPO will be offering a new tool for campus departments, the Subrecipient Commitment Form. The new form serves as a checklist that will assist faculty and staff in collecting required information from subrecipients. Key information about a subaward project will be in one place, including information about the subawardee organization (debarment, suspension, financial controls, A-133 compliance) and the proposed project (statement of work, budget, indirect costs, fringe benefits, compliance reviews, cost sharing). The form will enhance institutional compliance with federal regulations and UC policy (A-133, FFATA, BUS-43, etc.) and reduce audit exposure.

The Subrecipient Commitment Form is based on commitment forms now in use at many other universities, including other UC campuses. The form is completed by the subawardee’s sponsored projects office and PI, endorsed by the subawardee's authorized institutional representative, and provided at proposal stage with other proposal documents. It will eliminate the need for letters of commitment currently obtained from subawardees at proposal stage. All information requested on the form is already provided at some point in the proposal and award process, often after time-consuming research by the principal investigator, department, and SPO.

Before the new forms are put into use campus-wide in January 2009, SPO has asked several departments to participate in a two-month pilot of the forms and instructions. The pilot will also include an additional form to be used for contracts only, the Fair and Reasonable Cost Analysis/Sole Source Justification Form. This form, to be completed and signed by campus principal investigators, will provide information that is required by UC policy for research subcontracts under contract awards (UCOP Contract & Grant Memo 85-31 and operating guidance for BUS-43).

Feedback from the pilot will be incorporated into the process and procedures. For more information on or to participate in the pilot, contact Patricia Gates (pgates@berkeley.edu or 2-8109).

Members of the RAC subaward process analysis team are Patricia Gates, Jennifer Nadeau, Dan Jacobs, Nancy Han, Alaisha Hellman, Neil Maxwell, and Shelley Sprandel.

Future Plans

RAC is also working on revising additional subaward procedures, guidance, and forms, as well as continuing to make internal process changes to simplify and expedite research subaward processing. Newly learned business process analysis skills will also be applied to other processes used in SPO, Office for the Protection of Human Subjects, Office of the Animal Care and Use Committee, and Conflict of Interest Committee operations in the months to come. Look for more news in the next several months.