Research Administration Training Series

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Research Administration Training Series

• Subawards and Subcontracting
• March 24, 2011

presented by Brian PrindleDivision of Sponsored
Research
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Research Administration Training Series Goals of
Session

• Division of Sponsored Research
• Subrecipient vs Vendor Determination
• Overview of the Pre Award Subaward Process
• Frequently Asked Questions
• Contracts and Grants Accounting
• Post Award Subaward Process
• Invoicing
• Payment

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• Research Administration Training Series
• Subrecipient or Vendor Why is this Important?
• Impacts
• Documentation needed at the time of a grant
  submission.
• How you build your grant budget and apply
  indirects.
• Who you will work with at the time of award. DSR
  or Purchasing.
• What type of award is issued to the Subrecipient
  or Vendor.

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Research Administration Training
Series Characteristics of a Subrecipient?

• Subrecipient assists in the work being conducted
  by the University of Florida under the prime
  award.
• Subrecipient maintains prime responsibility for
  their own programmatic decisions.
• Subrecipient is part of the team.

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Research Administration Training
Series Characteristics of a Vendor

• Vendors provide the goods and services to many
  different buyers.
• Vendors operates in a competitive environment.
• Vendors are typically are for-profits. But not
  always.

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Research Administration Training Series
Still confused? Federal Circular OMB-A133 Says
Use discretion and good judgment when making a
determination
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Subrecipient Award Mechanism

• For a Subrecipient work with DSR and we use
• Subcontracts and Subawards
• ? DSR has Templates for both
• ? DSR completes with help from PI and PI staff.
• ? Authorized Officials for both Parties sign.
  For UF that is DSR.
• ? Terms and conditions of the prime agreement do
  flow down to the subrecipient.

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Vendor Award Mechanism
For Vendors you work with Purchasing and we use
Contract for Services, Purchase
Orders ? Coordinate with Purchasing ? You may
need to go out for Bid ? Sole Source
Justification ? DSR can grant an exemption to the
UF purchasing rules due to an emergency timing
issue.
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Research Administration Training Series
Lets Play? Subrecipient or Vendor
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What is it?

• Subrecipient or Vendor?
• University of Georgia Principal Investigator will
  be responsible for supervising a Post Doc and
  other personnel connected with the NIH funded
  project in the Atlanta area.
• UG staff will assist the UF research team with
  enrolling subjects into the NIH funded study from
  the Atlanta area.
• UG PI will participate with the UFs PI in the
  preparation of progress reports and manuscripts
  resulting from this study. UG PI will devote 25
  effort to this project each year.

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What is it?

• Subrecipient or Vendor?
• Scholastic Inc. will assist in the development of
  book collections for each book fair to be
  conducted at 17 elementary schools.
• The book collections will include appropriate
  titles for the cultural groups represented in the
  particular schools where the book fairs are held.
• Scholastic will send a representative to each of
  the participating schools to complete the
  ordering and fulfillment processes.

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What is it?

• Subrecipient or Vendor?
• The Investigator will be responsible for video
  taping mice to collect data in order to analyze
  taste reactivity. Monthly reports will be
  provided to UF.
• Investigator will play an integral role in the
  design and interpretation of the experiments and
  contribute to the preparation of manuscripts for
  publishing.

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Research Administration Training Series
Subcontracting Frequently Asked Questions
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What is needed at the time of Proposal?
A subrecipients proposal should include the
following

• 1) Endorsement from the Subrecipients Authorized
  Official.
• 2) A clear Description of Work to be performed by
  the Subrecipient.
• 3) A corresponding Budget and Budget
  Justification.

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• Subrecipients May Need to Provide Additional
  Information, such as
• Biographical Sketches of Key Personnel
• Current and Pending Support of Key Personnel
• Representations and Certifications
• Detailed Budget Information
• Negotiated Facilities and Administrative Rate
  Agreement
• Financial Conflict of Interest Disclosure Forms

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• Sole Source Justification
• The UF Principal Investigator, if required by
  the sponsoring agency, may need to provide a
  source selection justification.
• Unusual Circumstances
• Its not always straight forward. In those cases
  unusual circumstances contact DSRs Proposal
  Processing Office in advance and we can talk it
  through.

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Where do I budget for the Subrecipient Costs?

• When preparing the overall project budget,
  include the total costs of each subrecipient,
  which includes the subrecipients fringe benefits
  and indirect costs, as one line item in the UF
  direct cost budget.
• When using the federal modified total direct
  (MTDC) base, F A is calculated on the first
  25,000 of each new subcontract, only.
• When using a total direct cost (TDC) base, F
  A is calculated on ALL Subrecipient .

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Example (MTDC Base)
UF Salaries 200,000 Fringe
25,000 Travel 5,000 Supplies
10,000 Subrecipient (USF) 150,000 Total
Direct 390,000 (MTDC Base 390,000
125,000) 265,000 Indirect 46.5 MTDC
123,225 Total 513,225
exclusions 125,000 USF subaward
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Example (TDC Base)
UF Salaries 200,000 Fringe
25,000 Travel 5,000 Supplies
10,000 Subcontract (USF) 150,000 Total
Direct 390,000 (TDC Base 390,000) Indirect
25 TDC 97,500 Total 487,500
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Proposal Has been Funded WHAT HAPPENS NEXT?

• 1. Award is accepted and the Notice of Award
  (eNOA) is issued
• 2. DSR or OER Research Administrators (RA) will
  begin
• subaward process
• 3. RA will pull from the UF proposal the
  subrecipients
• scope of work and budget
• 4. RA will contact the PI or Departments Grant
  Specialist to
• confirm the details
• 5. Draft the subaward document using templates.

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• 6. Request CG Accounting to encumber subaward
  funding
• 7. Subaward draft is sent to PI or Department
  Grant Specialist
• for review, comments, and approval
• 8. Final subaward is sent to the subrecipient
  institutions
• Sponsored Programs Office for acceptance
• Upon return of signed subcontract, DSR fully
  executes
• 10. Fully executed agreement is distributed to C
  G Accounting, to the PI, and to the Department
  Administrator

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• Subcontract is Fully Executed
• Now What?
• Responsibilities of PI
• Stay in touch with subcontractors PI.
• Receive review technical report/deliverables
  from Subcontractor. Especially Finals
• Coordinate with CG Accounting the review and
  approval for payment of Subrecipients invoices.
• Review any requested changes in the budget,
  scope, project dates, and forward to DSR or OER
  for processing.

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CAS Regulations, Do they apply to a Subcontractor?
(Cost Accounting Standards)

• YES, if federal funds are the source.
• CAS is found in OMB Circular A-21, which is part
  of Flow through T Cs.
• Subcontractor is responsible for compliance with
  CAS

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Can a Subcontractor Carryover Unexpended Funds?

• YES, if the UF award allows automatic carryover
  and our PI agrees to flow this term down.
• At the direction of our PI, a specific clause
  can be added that subcontractor may NOT carryover
  of unexpended balances, without UF prior approval.

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Can a Subcontractor Grant itself a No-Cost
Extension?

• NO - the subcontractor may not grant itself a
  no-cost
• extension.
• If subcontractor requires an extension
• PI must give DSR approval to extend the end date
  of subcontract
• Subcontract date may not go beyond the UF end
  date.
• UF Award may need to be extended.

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Can a Subcontractor Grant itself Preaward Costs?

• Yes, if the federal prime award allows pre award
  and the terms of the subcontract do not remove
  the ability.

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How do IRB IACUC Rules Apply to Subcontractors?

• Subcontractors are responsible for compliance
  with IRB
• IACUC regulations
• Subcontractors upon request, will need to
  provide proof of
• IRB or IACUC approval at their institution
  before we will
• release subcontract funds.

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Can a Subcontractor Rebudget Funds without UF
Prior Approval?

• Depends
• FDP or Standard Research Terms - yes
• Expanded Authority- yes
• Fixed Price Subcontracts- yes
• Follow the rules of the prime award
• DSR can add special terms to not allow some costs
  without UF prior approval.
• For example Purchase of Equipment where
  Equipment was not budgeted for.

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What Happens when the Subcontractor is Not
Performing?

• PI works with Subcontractor
• - informally
• - formally
• Work with DSR
• - resolutions
• - terminations
• Terminations
• - for Breach of Contract
• - for convenience

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• What if the Subcontractor's PI leaves and we
  would
• like to have a new subcontract issued to the
  PIs
• new institution?
• Terminate early
• Final Report and Invoice
• Get Sponsor Approval if Necessary
• We did not include a subcontract in the
  original
• proposal but would like to issue a
  subcontract.
• What do we do?
• Contact DSR with questions. Most likely,
  UFs sponsor will need to approve, but not
  always.
• Will need a authorized subcontract proposal.
• Ship it off to the agency for approval or
  approve in house.

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What are some Key Elements of UF Subcontract?

• Payment Terms
• Reporting Requirements
• Audit requirements
• Allowable Costs
• Compliance Certifications
• Termination
• Modifications/Amendments
• Signatures of officials

• Subcontract number
• CFDA number
• Prime Award Number
• Type Cost or Fixed
• Project Directors
• Period of Performance
• Statement of Work
• Funding Amount

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Subawards and Subcontracting
Thats it for PreAward Questions?
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(No Transcript)
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The University of FloridaContracts and Grants
Accounting Services

• POST AWARD INFORMATION
• Processing Subawards Subcontracts
• March 24, 2011

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Subaward Contact Info 123 Grinter

• Deb Strickland
• 273-3486
• dstrickland_at_ufl.edu
• Ed Parker
• 273-3110
• champx4_at_ufl.edu
• Peg Canaday - Main
• 273-3091
• canadayp_at_ufl.edu
• Jerome Able IFAS EIES
• 273-3476
• jable_at_ufl.edu

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Subaward Overview

1. For CG_at_IFAS and CG_at_Main Awards Administration
   in the Division of Sponsored Research (DSR)
   prepares the subaward agreement and sends a
   request to encumber the funds to CG Accounting
   (CGA).
2. For CG_at_Engineering, the Office of Engineering
   Research (OER) performs this function. From this
   point on, CG Accounting handles all the subaward
   processing.
3. Note For this presentation, only DSR will be
   used in the steps that follow.
4. A purchase requisition is then prepared to
   encumber the funds in PeopleSoft.

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Subaward Overview

• Purchasing generates the actual Purchase Order.
  Unlike most POs, a copy is not sent to the
  subrecipient/vendor. The subaward agreement
  itself is their authorization to invoice UF.
• The subaward is entered into the Subaward
  Management Database a Microsoft Access
  application.
• Upon execution of the subaward agreement DSR
  sends a copy of the document to the UF Principal
  Investigator and CGA. Invoices cannot be paid
  until a subaward has been fully executed. (There
  is an example on the next slide.)
• We are now ready for receipt of the first
  invoice.

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Subaward Agreement
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Subaward Database History

• The University of Florida has developed an Access
  database that simplifies the monitoring of
  subawards. It is capable of importing files from
  PeopleSoft and the Federal Audit Clearinghouse
  (FAC) website. This facilitates keeping its
  data current.
• A Special Thank you to
• Nick Dunham
• Director of Information Services
• UF Office of Research

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The Subaward Database

• Why do we need the database?
• The database has a separate record for each
  subaward. Its contents are displayed using the
  Subaward Detail window, which has three
  functional tabs
• Prime Award Info Tab
• Subrecipient Info Tab
• Transactions Tab
• Examples of all three are next.

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Prime Award Info
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Subrecipient Info
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Transactions
Double Click Here for details
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Transaction Detail
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Subaward Database Documents

• Each subaward has a unique number. CG_at_IFAS and
  CG_at_Main use the format UFXXXXX.
  CG_at_Engineering subawards use UF-EIES.
• The database self-generates the following
• Subaward Summary Report
• Payment Certification Letters
• Regular
• Final
• Examples of both are shown next.

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Payment Certification - Regular
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Payment Certification - Messages
Please pay attention to anything written in the
text box shown below.
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Payment Certification - Messages
Please pay attention to anything written in the
text box shown below.
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Payment Certification PI input
Complete this section if the PI Approves the
invoice
Complete this section if the PI Declines payment
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Payment Certification - Final
Is this REALLY the Final ?
If not, X out the word Final before sending
the certification to CG
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Subaward Reports buttons
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Subaward Summary Report
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Payment Process for Invoices

• CGA reviews invoices received from the
  subrecipient for appropriateness of charges,
  dates of service, etc. If applicable, A-133
  Federal Audit Compliance must be determined
  before the first invoice is paid.
• The invoice is entered into the database. The
  Subaward Payment Certification and related
  documents are generated.
• The Payment Certification, invoice, and Subaward
  Summary Report are emailed to the department for
  PIs signature/approval.

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Payment Process for Invoices

• The PI indicates approval/denial on the Payment
  Certification letter. A justification, signature,
  and date are required. The letter is the only
  document we need to have returned. Please do so
  within 3 business days. or youll get a visit
  from THIS guy!

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Reasons for Delayed Payment

• The Certification letter is missing any of the 3
  requirements just listed on the previous slide
  or has not been returned at all.
• The subrecipient is not A-133 compliant according
  to the Federal Audit Clearinghouse, and has not
  returned the A-133 Compliance letter we send to
  them.
• Budget problems with the related PeopleSoft
  project, and/or the subaward itself.

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The invoice is now ready to be paid.

• A voucher is created by CG and the original
  invoice, payment certification, and bar code are
  faxed to Disbursement Services for audit, payment
  approval and archival imaging.

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Subaward PeopleSoft Accounts

• Subaward expenses are charged to account 712100
  ( first 25,000 if applicable ) and 712200.

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Helpful Information

• Agencies to which UF makes payments and their
  A-133 Audit Status are found at
• http//fa.ufl.edu/apps/cg/a133subaward/
• If a non-Federal entity will be expending Federal
  awards, they must be listed on this website
  before payments can be made.
• A-133 requirements may not apply to the
  subrecipient, but they still need to be on the
  website. Ill go into more detail as we review
  the next slide.
• Several forms related to subawards can be found
  on DSRs website at
• http//www.research.ufl.edu/research/forms.html

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The OMB A-133 Subaward Website
Spent lt 500,000
Foreign Entity
For Profit Company
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Thank you for coming!

• Any Questions?