Transcript Document
Managing Subrecipients August 8, 2013 What is a subrecipient? • For the purpose of this session, we are defining a subrecipient in the most general of terms. • A subrecipient is an entity engaged to perform work or services for a Prime Recipient using sponsor dollars. • For example, if SU receives an NSF award and determines that it needs the assistance of an outside entity, a subrecipient will be engaged. Sharing your work and funds? Yippee! Don’t forget there are strings attached! So, know the rules before you share!… Clearly define the work you are sharing! Best Practices for Monitoring Subrecipients • Document how your collaborators have been selected. • Define what work will be done and how much money will be paid for that work. • Be assured that entity/individuals you have selected are not debarred or suspended by the federal government. • Clearly define all reporting requirements. • Enter into a clear agreement documenting expectations. • Review all invoices prior to payment. Departments Responsible for Monitoring Subrecipients –Project Department –Office of Sponsored Programs –Office of Sponsored Accounting –Purchasing So… Who does what?? It depends… Do you know what mechanisms (form of agreement) are used to engage subrecipients? Subaward, Vendor or Consultant? • Subawards/Subcontracts – – – – – Make programmatic decisions within the agreed upon scope of work Would be considered a PI or Co-PI if at SU Minimal direction from SU Measured against prime sponsor requirements Work benefits the sponsor • Vendors/Purchased Services – – – – Provides required services as a normal course of business Operates in a competitive environment Measured against the agreement with SU Serves SU’s needs with a high level of direction • Consultants – – – – Individual Provides advice based on expertise Measured against the agreement with SU Serves SU’s needs Indicators of Subawards, Purchased Services and Consultants Purchasing and Subrecipients • University Policy Requires Competitive Bidding – Considerations include price, quality, insurance, specification compliance, delivery terms and conditions, bidder experience and reputation. – A request to waive competitive bidding procedures requires documented justification, and any waiver requires approval by the Director of Purchasing or his designee. • Document of Sole Source selections – A sole source procurement occurs when restriction to a single brand is justified and the Purchasing Office has determined that the item(s) is only available from a single source. – Purchasing is still required to determine that the price is fair and reasonable. We do this by negotiating price, securing published price lists for comparison, and/or comparing the price of similar purchases. Engaging a Consultant • PI/Project Staff Responsibilities – Submit the Consulting Agreement with attachments outlining: • • • • the service to be provided; the number of days of service involved (per year, if applicable), the daily rate of compensation, and whether travel will be separately itemized. – Setup Consultant Commitment and process appropriate invoices • OSP Responsibilities – Review submitted documentation – Assure that the Consulting Agreement is complete and fully executed Engaging a Vendor • Managed by Department Staff – OSP does not have a role in this form of collaboration however, OSA will pre-audit expenditures on sponsored projects • Must follow University Purchasing Policies – Work with the Purchasing Department • Purchasing Policies can be found at this link: Purchasing Policies Issuing Subawards • PI/Project Staff Responsibilities – Initial Step • Submit Request to Issue a Subaward – On-going Activities • • • • Monitor quality of work/progress Approve Invoices Submit Request to Modify a Subaward Approve Closeout • OSP Responsibilities – Initial Step • Subaward Negotiations • Subaward Commitment Setup – On-going Activities • Federally mandated Subrecipient Monitoring Processes • Pre-Audit Invoice Review and Processing • Closeout Additional Subrecipient Monitoring of Subawards • Entity based Subrecipient monitoring – Who are we monitoring? • All active subrecipients receiving sponsored funds from SU – When are we monitoring? • Requesting documents initially and annually thereafter • Monitoring continually throughout the years – What are we monitoring? • • • • • • Syracuse University Research Subrecipient Profile F&A/Fringe Benefit Rate Agreement A-133 Single Audit/ Financial Statements Debarment/Suspension Review SAM/ previous CCR Registration SU Risk Assessment Questions?