Transcript Slide 1

Don’t Let Subawards Sink You!
Judy Krzyzek & Karen Sachi
Office of Sponsored Projects Administration
What makes a transaction a subaward?
• A defined portion of the Statement
of Work is assigned to another entity
• Work performed by subrecipient’s
personnel using their resources
• Subrecipient takes full responsibility for completing
the assigned work, including intellectual leadership
• Subrecipient must comply with the terms of the prime
award
Other Purchasing Actions
• Provide goods and services as part of normal business
• Provide similar goods and services to others
• Operate in a competitive environment
• Goods and services are ancillary to the sponsored
project
• Will not be subject to the terms of the prime award
PI Evaluates Potential
Subrecipients
How is the subrecipient selected?
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Past performance
Technical/financial resources
Proposed scope of work
Reasonableness of proposed costs
PI/Department Prepares the Proposal
• Integrates the subrecipient’s statement of work and
budget into U of M’s proposal
• Obtains signed commitment from proposed
subrecipient’s research office
• Provides sole source justification (required for federal
contracts)
• Provides other forms required by sponsor
SPA Reviews Proposal
• Verifies subaward is the appropriate
mechanism
• Reviews budget (F&A, cost sharing)
• Verifies proposal documents are provided (e.g. written
commitment from institution)
• Verifies proposal complies with sponsor and University
policies
• Endorses and submits the proposal
Information needed from
Departments to Issue a Subaward
• Collaborator and contact
information
• Statement of Work
• Budget, including
cost sharing commitments
(if applicable)
• Technical/financial reporting
requirements
• Payment terms/schedule
(if applicable)
• Period of Performance
• Verification that
subrecipient is compliant
with IRB, IACUC, approvals
(if applicable)
• Sole source justification
(if applicable)
• Cost/price analysis
• FFATA data (if applicable)
FFATA: Federal Funding
Accountability and Transparency Act
• Searchable website for the public to identify funding
by data elements. Public must be able to:
– Ascertain amount of federal funding awarded to an entity
– Download results of search
• Award data must be available by Jan 08 (Feds)
• Subaward data must be available by Jan 09 (Us)
• Data elements:
DUNS#
Program Source
Entity Name
Title
Transaction Type
Primary Performance Location
Award $
DUNS # of Parent
NAIC or CFDA#
Funding Agency
Location of Entity
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Data Elements
Name of Entity Receiving Award – Official, legal name
registered in DUNS and CCR.
Award Amount – Federal award amount.
Transaction Type – Loan/cooperative
agreement/contract/guaranteed loan, etc.
Funding Agency – The Federal agency you received the
grant money from.
NAIC – Not applicable to grants.
CFDA No. – CFDA number assigned to the program.
Program Source – [This code is not applicable to nonFederal entities. The Federal government assigns and uses
this code internally.]
Award Title Description with the Purpose of Each
Funding Action – Aside from the general Federal definition,
this field is used to further define the award.
Location of Entity Receiving the Award – Self
explanatory (city, state, congressional district, country).
Primary Location of Performance – Provide the primary
location where the work is being performed (city, state,
congressional district, country).
Unique Identifier of Recipient – DUNS +4.
Parent ID – DUNS
Potential High Risk Indicators
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A qualified audit report, or failure to have a current audit report
Inadequate response to a financial questionnaire
History of non-compliance
History of non-performance or failure to use funds for their authorized
purposes
New subrecipient (or new to this type of project)
New personnel or systems
Large subaward/large percentage pass through
Award size relative to subrecipient’s sponsored
research portfolio
Criticality to overall success of pass-through entity’s
project
Subrecipient in a remote location
Type of subrecipient
(is the subrecipient already subject to A-133)
Monitoring Responsibilities: PI/Dept
• Understands terms and
conditions of subaward
agreement
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Verifies compliance approvals are
current for subrecipient’s portion of
statement of work (human subjects,
animal subjects, biosafety)
• Serves as primary point of
contact for the Subrecipient
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Personally approves invoices for
payment
• Monitors scientific progress
• Verifies that the Subrecipient is
meeting cost sharing
commitments
– Ensures all costs are allowable,
allocable and reasonable
– Ensures all costs were incurred
within the period of performance
of the subaward
– Confirms that expenses are
aligned with technical progress
Monitoring Responsibilities: SPA
• Assists PIs with
monitoring subawards
• Reviews annual audit
reports
• Verifies corrective action
plans are implemented
(if necessary)
• Reviews risk levels and,
if necessary, modifies
subaward agreements
• Verifies invoices are
signed by PIs, costs
incurred within dates,
amounts, and pursuant
to terms of subaward
Modifications and Terminations
PI/Dept:
• Assesses need to modify
statement of work, budget,
period of performance
• Works with SPA in a timely
manner to arrange
amendment
• Provides information to SPA
(budgets, dates, reporting
requirements, etc.)
• Assists SPA in negotiating
changes, if needed
SPA:
• Prepares amendment
• Negotiates changes
• Modifies the encumbrance in
the financial system (if any)
Planning for Closeout: PI
• Checks status with subrecipient 90 days before end
(best practice)
• Follows up on late or missing reports or deliverables
• Obtains final invoice (marked FINAL)
• Sends copy of final invoice to SPA
Processing Closeout: SPA
• Reviews and processes payment of
final invoice
• De-obligates commitment for
subrecipient agreement (if
necessary) in financial system
• Audits subaward (if necessary)
On the Horizon
• Web-based forms and resources
• Sole source justification requirement
• Enhanced subaward database (SPA)
• Increased risk monitoring of
subrecipients
• Expedited collection of FFATA data
elements
Thank You!
Questions?
Any
Contacts
• Sponsored Projects information: 4-5599
• Sponsored Projects Directory:
http://www.ospa.umn.edu/directory.html