DSP: Wendy Beaver GAO: Jodi Kennedy June 12, 2015

Kathie Gonzales Angie Klein

Britt Murdock

Edie Pierce-Thomas

Angi Roemerman

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DSP Subaward Website http://dsp.research.uiowa.edu/subawards-uni

versity-iowa

Process Flow Chart Roles & Responsibilities Subaward Forms UI Outgoing UG Subaward Quick Guide

DSP Staff Directoryhttp://dsp.research.uiowa.edu/dsp-staff-directory

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2 CFR 200.74 Pass-through entity means a non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program. 2 CFR 200.74

2 CFR 200.92 Subaward means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass-through entity.

2 CFR 200.93 Subrecipient means a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program.

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2 CFR 200.23 Contractor means an entity that receives a contract as defined in 2 CFR 200.22.

2 CFR 200.22 Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award (e.g., a purchase order at the UI). The term does not include a legal instrument when the substance of the transaction meets the definition of a Federal award or subaward.

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Pass-through entity is responsible for deciding whether an arrangement is a subaward, contract, or consulting arrangement.

Subaward: Carrying out intellectually significant portion of the federal award; Key personnel may be considered authors on publications; work requires IRB or IACUC approval.

• Processed through DSP

Contract: Obtaining goods and services; procurement relationship; provides a routine service in a competitive environment; provides similar goods or services to many different purchasers.

• Purchase order issued by UI Purchasing

Consulting: Advisory services • Professional Services Agreement issued by UI Purchasing

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Additional resources: • DSP Subaward website

http://dsp.research.uiowa.edu/subawards-university-iowa • FDP Checklist to Determine Subrecipient or Contractor

Classification

Determining the appropriate relationship at proposal stage is critical to ensure appropriate accounting for costs and compliance requirements.  Misclassification may result in delays in proposal submission, subaward processing, inaccurate calculation of costs (e.g., failure to include or exclude F&A costs), and require additional time to request approval for project changes.

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PI has initial responsibility to determine collaborator’s status

PI/Department are encouraged to consult with DSP in advance of proposal submission

Collaborating with individuals or sole proprietors: Professional Services Agreement (PSA) through UI Purchasing

Collaborating with another UI department (this is not a subaward handled through DSP)

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Include Subrecipient’s budget and other required information in the UI proposal (i.e., budget justification, Letter of Intent, etc.)◦ Consult with potential Subrecipient sites prior to proposal submission to

obtain accurate budget information for proposal.

Consider sponsor requirements:◦ Forms◦ Budget categories◦ F&A◦ Conflict of Interest in Research◦ Fixed Price Subawards under the Uniform Guidance◦ Other requirements in funding announcement

Fixed Price subawards must be explicitly and clearly requested in the Proposal with proper justification.

We don’t want costs disallowed by the Sponsor-be prudent & detailed in your justification & budget request.

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Subrecipient’s federally negotiated F&A rate must be used on subawards unless a lower rate for the project is published by the sponsor (e.g., NIH caps F&A for foreign subrecipients at 8%).

For subrecipients without a federally negotiated F&A rate, 10% MTDC F&A rate must be used on federal awards.

NSF-if a subrecipient does not have a U.S. federally negotiated F&A rate, the 10% de minimus rate must be used (no less as that is considered voluntary committed cost sharing which is not allowed). This new rule applies to foreign subrecipient sites as well.

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2 CFR 200.332, 200.201

Prior written approval from Federal awarding agency (Note: if Fixed Price Subaward was in original proposal NIH’s award notice constitutes approval, all other agencies must have specific approval)

Cannot exceed $150,000 cumulatively (simplified acquisition threshold)

Fixed Price subaward amounts do not fall under the re-budgeting authority. Sponsor approval is required to move funding to or from this category.

Fixed price amount is negotiated using cost principles or other pricing information as a guide

Fixed price subawards are not allowed if there is mandatory cost sharing or match

At the end of the subaward, subrecipient must certify the project or activity was completed or the level of effort was expended

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If Subrecipient is other than U.S. university, send the Audit Certification and Financial Status Questionnaire to Subrecipient

PI negotiates scope of work and budget with Subrecipient

Statement of work conforms to requirements of Prime Award

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If Subrecipient is a new vendor to the UI, send Vendor Application Form to Subrecipient

If Vendor is in database, but new address is needed, e-mail Purchasing Vendor File Team (VFT) purchasing-vendor@uiowa.edu with Vendor name, new address, phone, and contact person.

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If there will be an Advance Payment to the Subawardee, review the Advance Payment instructions, requirements and UI established payment schedule.

Advance Payments ◦ PI Subawardee Monitoring Assurance◦ Subawardee Request for Advance of Funds◦ Requires DSP and GAO approval◦ Once PO is created PI/department must complete

“Advance Payment Request Form” to process first payment

◦ Initial payment is 20% of annual award + equipment; Quarterly payments thereafter

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Use Category Code 99990000 – specific for Subawards List subaward period of performance dates List direct and F&A cost figures for the subaward budget period Attach the statement of work Attach the detailed budget, including supporting documentation for

fringe benefits if not federally negotiated Attach the Subaward Reporting Requirements form (required for

subawards and amendments under federal grants).  This form is recommended for other subawards. PI should determine reporting periods.

Attach Audit Certification and Financial Status Questionnaire (required for Subawardees other than U.S. accredited institutions of higher education)

Attach other documentation as required by prime award If replacing an existing PO, list the previous PO number If requesting advance payment, attach advance payment forms Route the Preq through Workflow

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DSP drafts the subaward

UI prefers to issue cost-reimbursement subawards

Fixed price subawards under the UG have specific requirements and limits

Generally UI follows the prime award type of agreement

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Subrecipient should submit invoices directly to GAO for payment◦ B5 Jessup Hall, Iowa City, Ia◦ uigao-subawardeeinvoices@uiowa.edu

Cost-reimbursement subawards – subrecipient invoices the UI no more often than monthly

Subawards that include an Advance Payment schedule – subrecipient invoices the UI quarterly; monthly/quarterly financial reports must also be submitted

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GAO reviews invoices and sends to Accounts Payable for payment◦ Invoice adequately meets UI invoice requirements ◦ Invoice includes Certification statement and is signed◦ Invoice period falls within the Subcontract budget period◦ Reviews invoices for consistency with subaward budget

PI/Department receives notification from Accounts Payable that a Subaward invoice requires “Receipt” ◦ Review invoices for consistency with subaward budget◦ Assess that invoice is reasonable in light of subrecipient progress ◦ Assure compliance with the terms of the prime award◦ “Receipts” voucher and approves payment through the e-Pro

system

PI/Department contacts AP and GAO immediately with questions or if payment of an invoice should be placed on hold

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PI, Department and GAO all have monitoring obligations

PI receives progress and invention reports

PI maintains documentation of review (email, annotation with “reviewed” and date)

PI maintains subrecipient reports and other documents for the required document retention period (for federal awards generally three years from the project end date)

PI monitors financial and programmatic progress of subrecipient

PI notifies DSP and GAO immediately with concerns involving subrecipient performance

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Annually GAO requests and reviews subrecipient audits and/or financial reports◦ GAO may determine additional documentation or reporting

requirements are needed◦ GAO works with DSP if changes are needed

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Grant Accounting sends a copy of the final invoice to the PI and Department for approval before sending to Accounts Payable◦ PI/Department confirms completion of work◦ PI/Department reviews final expenses◦ PI/Department assures all required progress and invention

reports have been or will be received

Fixed Price subawards only - GAO requests Certificate of Completion from subrecipient

If necessary, Department and GAO work with AP to close Subaward PO

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http://dsp.research.uiowa.edu/revising-existing-subaward

BR (Budget Reference) for the prime award is indicated on the AAAN

If the BR has not changed from the previous subaward, submit a Subaward Amendment Request Form

If the BR has changed from the previous subaward, submit a new Preq

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If the BR does not change◦ The UI’s default is to add new funding to the previously

authorized subaward amount (i.e., the UI automatically approves carryover of unexpended funds).

◦ If the PI/department does not want to authorize carryover, contact DSP before submitting the subaward amendment request form

If the BR changes◦ The UI’s default is not to authorize carryover◦ If carryover is requested, contact DSP

Sponsor approval Confirmation of the amount of unexpended funds PI’s approval

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Effective Dec. 26, 2014, 2 CFR 200 (replaces A-21, A-110, and A-133)

Does the UG apply to my federal grant?

NIH and NSF: UG applies to award notices dated 12/26/2014 or later that provide funding

ONR: If the award notice provides incremental funding for an existing award and the initial award was issued prior to 12/26/2014, the UG does not apply. If the award notice provides funding and does not meet the above existing award criteria, the UG applies.

Other federal agencies: If an award notice was issued on or after 12/26/2014, the UG applies

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No commingling of federal and non-federal funds (i.e., only 1 MFK per Preq) under awards subject to the UG

Additional subrecipient risk assessment monitoring

UI financial questionnaires have been revised to reflect UG rather than A-133 requirements:

New audit threshold is $750,000 in federal financial assistance

Invoices must include new certification as required in 2 C.F.R. 200.415(a)

Required documentation of UI PI’s receipt and review of Subrecipient progress and invention reports

Certificate of Completion required for Fixed Price Subawards

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GAO is working with AP to add assurances to the voucher Receipt notification email ◦ May also add assurances to the Receipt process within e-Pro

Starting July 1, all final subrecipient invoices will be sent to the PI and Department Administrator for approval ◦ PI will always be included on the email◦ Email will clearly state that by approving final payment, the

PI is assuring completion of work and expenses and their retention of required reports

GAO will require Certificate of Completion for Fixed Price Subawards

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FDP Subaward Templates http://sites.nationalacademies.org/PGA/fdp/PGA_063626

DUNS number is referred to as “Unique entity identifier”

Central Contractor Registration (CCR) and Excluded Parties List System (EPLS) no longer exist as standalone systems; functionality is included in System for Award Management (SAM)

Attachment 4, Reporting Requirements

Attachment 6, UI specific terms – See screen shots for images of the new face page and where the G/P number, Preq & PO numbers appear on Attachment 6.

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DSP Research Tracker Search by:

◦ ReqID Number◦ PO Number◦ Subrecipient Name◦ UI PI Name◦ UI Grant/Program Number◦ UI Sequence Number

Click on “project”, then Expand Out Going Subawards (click on “+”) to see status information

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Division of Sponsored Programs (DSP) 2 Gilmore Hall Phone: 335-2123 Email: dsp-contracts@uiowa.edu

Grant Accounting Office (GAO) B5 Jessup Hall Phone: 335-3801

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