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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? • • • • 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 • • • • • • • • • • • • 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 • • • • • • • • • • • 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 • 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 • 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