Transcript Slide 1

Office of Sponsored Programs
May 21, 2011
[email protected]
X2807

Help us learn about you

Review Sponsored Project lifecycle & guiding
principles
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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
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Spending Federal Dollars
◦ Comes with strings attached
◦ Want to avoid knots or the noose
 Why??
◦ Fed’s expectations: ??
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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
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BBI’s organizational structure
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Folks roles/responsibilities
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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
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How & Who?
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COS
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Go / no go process
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IRIS
Who notifies OSP
(MMcB) about plans &
when ?
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Grants.gov / fbo.gov
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BBI’s activities
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Distribute to BBI
leadership
OSP
Negotiate
Find FOA
Apply
Award &
Set Up
Manage
Award
Close-out
& Repeat
or
Recompete

Who’s responsible for
what?
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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
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Internal Review
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◦ Application adherence
◦ What is goal of project?
◦ Who has expertise?
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◦ 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…
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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
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Subrecipient
◦ Responsible for work and award performance
◦ Subject to certifications/assurances (Human Subjects)
 If at SU – would be PI or other key personnel
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Vendor
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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”
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Made up of many parts…
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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
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BBI’s responsibilities / tasks
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Subrecipient process  under award
management
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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?
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Compliance check
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◦
◦
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Human subjects congruence
COI all folks
Debarment/suspension
IRR
etc
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No Internal Routing and Review form
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No current COI for key personnel
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Human subjects protocols pending
◦ Allocate $$ (easier if clear up front)
 Human Subjects
 Not Human Subjects
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Allocation of award to multiple SU units not
clear
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OSP  OSA for Chartstring creation (new
award)
OSP  BBI PI, budget manager & project
manager
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Award package: chartstring, T&C etc.
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New – OSP will confirm with BBI that any 3rd party
partners are the same as in proposal
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OSP will request institutional profile & conduct risk
assessment
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When GRANT agreement isn’t in hand –
request as soon as known and practical
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Contracts: only when we know start date and
it’s not effective dated; high risk
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Same compliance reviews as for awards
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Not allowed
◦ Subrecipient costs
◦ Human subjects costs without congruence complete
Negotiate
Find FOA
Apply
Award
& Set Up
Manage
Award
Close-out
& Repeat
or
Recompete
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Responsibilities
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Negotiate amendments
◦ Day-to-day
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Obtain sponsor prior
approvals
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Facilitate (sub)award
administration
◦ PI
◦ Financial
◦ Subrecipient
◦ Consultants
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Information management
BBI
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Facilitate compliance
with SU / sponsor’s
policies, T&C
OSP
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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
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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
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From risk assessment, develop subaward
◦ Cost reimbursable vs fixed price WHY
◦ Reporting requirements
◦ Financial supporting docs etc
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Execute subagreement
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Create PO in ePro
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Set up in SADb
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Send subagreement to BBI
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Monitor ‘process’
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Managing your Award
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Award Management Aid
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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
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Issue New subaward
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Modify Existing subaward
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Proposed- Subaward materials Transmittal
Questions frequently asked of OSP
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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
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Invoice review guidance
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Continuation…
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Annual Progress report
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Complete ‘continuing
application’
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HINT: Work with sub’s
same time to obtain
updated SOWs and
budgets for next budget
period (~90d out)
Carry over?
BBI
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Signs as authorized
official or AOR, as
required.
Reviews /approves
budgets
Requests carry over, as
applicable
OSP
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OSP not informed of continuation process
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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
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Baton gets dropped along the way – Communications / info
management challenges
◦ Agreement execution
◦ Invoice management
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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
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Accepting federal $$ comes with MANY obligations,
i.e there are strings attached.
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Current administration –
◦ Transparency and accountability to avoid Fraud, Waste, and
Abuse
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Braiding and blending is not consistent with the
allocobility cost principle
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You will be audited.
◦ Following regulations, policies & SU procedures; timely
actions; and complete documentation are best protections
against questioned costs, embarrassment, loss of
reputation etc.
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Late awards to SU
◦ Impacts subawards
◦ Effort Reporting
◦ Cost transfers – too many, and not timely
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Debarment & suspension
◦ Must be done prior to hiring
◦ Sub’s – we ask for certification, but they are
responsible for conducting epls check
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Effort – personnel compensation and supplemental
pay (Extra Service)
◦ Subawardee effort procedures
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Travel – especially foreign travel
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Recharge Centers
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Subrecipient monitoring
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Administrative costs
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Eligible activities
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Accepting federal $$ 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…