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…