Transcript Slide 1
Office of Sponsored Programs
May 21, 2011
[email protected]
X2807
Help us learn about you
Review Sponsored Project lifecycle & guiding
principles
Strategize on how to more efficiently work together
to
◦ BBI’s organizational structure
◦ Folks’ roles/responsibilities
◦ How you operate at various stages of the lifecycle
◦ Facilitate achieving the award’s goals & objectives while
adhering to sponsor’s requirements & SU policies /
practices
Spending Federal Dollars
◦ Comes with strings attached
◦ Want to avoid knots or the noose
Why??
◦ Fed’s expectations: ??
At proposal submission – SU agrees to follow award’s
terms and conditions including following SU
policies/procedures, reporting requirements & the
cost principles, which require that costs are:
Allowable – under terms of award and SU or entity policy
Allocable – can reasonably determine benefit received by award
and cost proportional to benefit
Reasonable – prudent person test (necessary)
Consistently treated – either direct cost or indirect cost
BBI’s organizational structure
Folks roles/responsibilities
How you operate at various stages of the
lifecycle including communications &
information management
Find FOA
Apply
Negotiate
Award &
Set up
Manage
Award
Close-out
& Repeat
or
Recompete
How & Who?
COS
Go / no go process
IRIS
Who notifies OSP
(MMcB) about plans &
when ?
Grants.gov / fbo.gov
BBI’s activities
Distribute to BBI
leadership
OSP
Negotiate
Find FOA
Apply
Award &
Set Up
Manage
Award
Close-out
& Repeat
or
Recompete
Who’s responsible for
what?
Needs
◦ FOA information ASAP
URL
PI & team
Partners (non-SU)
Ltr of Com’tnt AOR
SOW
Budget required format
◦ Time to review &
authorize
7 b-days: budget
3 b-days: complete app
◦ Service guidelines
BBI
OSP
Internal Review
◦ Application adherence
◦ What is goal of project?
◦ Who has expertise?
◦ IRR congruence
BBI?
Collaborators??
What is each group doing?
Cost? Parts and whole
◦ Confirmation of 3rd party
approvals
◦ FAR exceptions
◦ Info Management
Version control
Naming conventions
BBI
Reviews
◦ Lots of other stuff…
Submits
OSP
Decision to be made at proposal stage.
◦ Not all treated the same in terms of F&A
◦ Regardless of Type of 3rd party relationship –
In advance, have a SOW or at a minimum a clear
understanding of what they will do for you
◦ Characteristics of subrecipients, Vendors (purchased
services) or consultants
Lots of detailed information
Subrecipient
◦ Responsible for work and award performance
◦ Subject to certifications/assurances (Human Subjects)
If at SU – would be PI or other key personnel
Vendor
Consultant
◦ Services provided are core to their mission
◦ Provide same services for many customers
◦ Price published or same rate for similar customers
May be non-profit organization
Caveat – IHE’s procedures may impact agreement type
◦ Individual who provides advice or discrete service
modest scale
A type of vendor in terms of award T&C (e.g., not subject to
human subjects assurances but may be subject to
confidentiality provisions.)
Is “work for hire”
◦ Use ‘worksheet for non-SU employees”
Made up of many parts…
Much of our focus is on:
◦ Project plan – narrative, description etc
Including Statement of Work (SOW)
◦ Budget
◦ Budget justification
Budget
SOW
SOW
Budget is financial expression of statement of work (SOW).
Work drives costs; each collaborator should define & “own” SOW
SOWs from each individual component
SU
Sub#1
Sub#2
Sub#3
PurchSvc#1
PurchSvc#2
Cons't#1
Cons't#2
Find FOA
Apply
Negotiate
& Set Up
Award
Manage
Award
Close-out
& Repeat
or
Recompete
OSP responsibilities / tasks
BBI’s responsibilities / tasks
Subrecipient process under award
management
Grants / Contracts–
◦ Standard Terms & Conditions or Troublesome clauses
(reviewed and identified at proposal submission)
◦ Where FAR exceptions accepted?
◦ Was there a modification to submitted budget or work
plan?
Adjust key personnel effort
Modify scope of work
Allowable costs?
Compliance check
◦
◦
◦
◦
◦
Human subjects congruence
COI all folks
Debarment/suspension
IRR
etc
No Internal Routing and Review form
No current COI for key personnel
Human subjects protocols pending
◦ Allocate $$ (easier if clear up front)
Human Subjects
Not Human Subjects
Allocation of award to multiple SU units not
clear
OSP OSA for Chartstring creation (new
award)
OSP BBI PI, budget manager & project
manager
Award package: chartstring, T&C etc.
New – OSP will confirm with BBI that any 3rd party
partners are the same as in proposal
OSP will request institutional profile & conduct risk
assessment
When GRANT agreement isn’t in hand –
request as soon as known and practical
Contracts: only when we know start date and
it’s not effective dated; high risk
Same compliance reviews as for awards
Not allowed
◦ Subrecipient costs
◦ Human subjects costs without congruence complete
Negotiate
Find FOA
Apply
Award
& Set Up
Manage
Award
Close-out
& Repeat
or
Recompete
Responsibilities
Negotiate amendments
◦ Day-to-day
Obtain sponsor prior
approvals
Facilitate (sub)award
administration
◦ PI
◦ Financial
◦ Subrecipient
◦ Consultants
Information management
BBI
Facilitate compliance
with SU / sponsor’s
policies, T&C
OSP
Review all expected obligations upon receipt of award
materials
◦ ALL BBI personnel effort: review / revise upon receipt of
every new award and anticipated award.
◦ 3rd party collaborations – plan ahead
◦ Standing orders – plan ahead
Avoid confirming invoice attached
Not named folks debarment / suspension (epls.gov)
Review award materials especially terms and
conditions to know what you can & can’t do.
DoL & cooperative agreements much less flexibility
◦ You can’t move named personal around at will.
◦ CONSIDER – name only essential folks
Proposal
Award –
Commitment:
OSP BBI: Same 3rd parties?
SOW
BBI: Req 2 Issue & refine/ revise
SoW & Budget
Budget &
Justification
OSP: Request Profile & conduct
risk assessment
OSP: Develop
Subaward,
Negotiate,
Execute
Set up PO
Manage /monitor
subawards
BBI: Progress
Approve $$
OSP: costs,
timing, pace
From risk assessment, develop subaward
◦ Cost reimbursable vs fixed price WHY
◦ Reporting requirements
◦ Financial supporting docs etc
Execute subagreement
Create PO in ePro
Set up in SADb
Send subagreement to BBI
Monitor ‘process’
Managing your Award
Award Management Aid
Collaborators
◦ Letters of commitment from authorized rep.
Partner may reject award
Certs & Assurances not obtained from subaward delays
◦ Budget / budget justification
Financial risk
◦ Statement of work missing or
◦ Ambiguous standards of performance
◦ Not unique to project
Errors in management
“Braiding & Blending” allocobility concerns
Issue New subaward
Modify Existing subaward
Proposed- Subaward materials Transmittal
Questions frequently asked of OSP
Why am I not being paid???
◦ There is no agreement in place
No agreement – no obligation by SU
◦ No invoice has been received
No invoice – no way to pay
Invoice review guidance
Continuation…
Annual Progress report
Complete ‘continuing
application’
HINT: Work with sub’s
same time to obtain
updated SOWs and
budgets for next budget
period (~90d out)
Carry over?
BBI
Signs as authorized
official or AOR, as
required.
Reviews /approves
budgets
Requests carry over, as
applicable
OSP
OSP not informed of continuation process
Subaward continuation challenges
◦ Not done in a timely manner
◦ Ambiguous statement of work
◦ SOW similar to other awards
◦ Budget poorly justified with little linkage to SOW
◦ Inadequate budget justification
Baton gets dropped along the way – Communications / info
management challenges
◦ Agreement execution
◦ Invoice management
Formal process to ensure that all University
obligations to sponsor have been met.
◦ Programmatic
All required reports
Invention reports
◦ Financial
Final Financial report
Review all documentation
Property Reports
◦ Subaward – as above
Accepting federal $$ comes with MANY obligations,
i.e there are strings attached.
Current administration –
◦ Transparency and accountability to avoid Fraud, Waste, and
Abuse
Braiding and blending is not consistent with the
allocobility cost principle
You will be audited.
◦ Following regulations, policies & SU procedures; timely
actions; and complete documentation are best protections
against questioned costs, embarrassment, loss of
reputation etc.
Late awards to SU
◦ Impacts subawards
◦ Effort Reporting
◦ Cost transfers – too many, and not timely
Debarment & suspension
◦ Must be done prior to hiring
◦ Sub’s – we ask for certification, but they are
responsible for conducting epls check
Effort – personnel compensation and supplemental
pay (Extra Service)
◦ Subawardee effort procedures
Travel – especially foreign travel
Recharge Centers
Subrecipient monitoring
Administrative costs
Eligible activities
Accepting federal $$ brings with it the
obligation to be responsible steward of those
$$
Efficient and effective practices facilitate
stewardship
Strategize / document what can we each do
to support this goal…