Office of Sponsored Programs All rights reserved GTRC The New OSP Request for Subaward & Subrecipient Monitoring Course Dana Simpson: Contracting Officer,

Office of Sponsored ProgramsAll rights reserved GTRC

The New OSP Request for Subaward & Subrecipient

Monitoring Course

Dana Simpson: Contracting Officer, Sub-agreements TeamRob Roy: Director of Board of Regents Sponsored ProgramsGarrett Steed: Training Program Manager


Subrecipient Monitoring

Overview

Definitions and policies– Georgia Tech’s policies– Subrecipient– Request for Subaward– Vendor– Roles– Responsibilities– Risk– Authorization



Georgia Tech’s Responsibility

Georgia Tech is responsible for ensuring that all subrecipients of its sponsored research awards are in compliance with applicable requirements.



Georgia Tech’s Guidelines



Who is a Subrecipient

OMB A-133OMB A-133: A Subrecipient is a legal entity to which a sub award is made and which is accountable to the recipient for the use of funds provided.

Financial assistance, or procurement , or contract made by a recipient to an eligible Subrecipient



Subrecipients vs. VendorsOMB A-133 B.210Federal award. Characteristics indicative of a

Federal award received by a subrecipient are when the organization:

(2) Has its performance measured against whether the objectives of the Federal program are met;

Payment for goods and services. Characteristics indicative of a payment for goods and services received by a vendor are when the organization:

(1) Provides the goods and services within normal business operations;

(2) Provides similar goods or services to many different purchasers;

Design and Develop (Sub) vs. Configure (Vendor)

http://www.whitehouse.gov/omb/circulars/a133/a133.html#b



Subrecipients vs. Vendors

Vendors are Not Subrecipients: and therefore do not include the purchase of goods and services

Entities with in the USG can be an exception to this rule

Design and Develop (Sub) vs. Configure (Vendor)



Identifying eligible Subrecipient entities

That are willing and able to comply with the requirements of the awardHave accounting systems that are adequate to administer the awardHave not been suspended or debarred from receiving federal funds



Preparing a Statement of Work: SOW

The Statement of Work is a document that:– lists and describes all essential and technical

requirements for the effort to be performed– including standards to be used to determine

whether the requirements have been met.

Set your expectation and reporting requirements early, put them in the sub-award



SOW should include:

Objective or PurposePeriod of PerformanceMilestonesA list of detailed work requirementsWorkload requirementsPersonnel requirementsResources (if any) to be furnished to the subcontractor



Process Flow

Identify need for Subaward

Formal Request

Submit Formal

Request

Review Request

Prepare & Send

Proposal

ReviewProposal

Accept &Incorporate

Into Proposal

Submit Proposal

App.

Enter Subaward Request Into

WebWise System

Review and AffirmCompliance Approve

Review Terms

Communicate with PI & support staff to

address issues

Accept or Negotiate Terms

Addressed?

Find New Subaward

PD

/P

IP

D/

PI

OS

POS

PS

ubS

ub

Pre-award Post Award

Subaward Executed

No

Yes

Yes

Yes

No

No



Beginning a Sub Agreement Process

To initiate: you willneed to log into WebWise, using your GT account ID and Kerberos password. Under the OSP Contract Information System tab you will find a section for Subagreement Management.



Step 1 To complete an on-line "Request for a Sub-Agreement" you will need to have– a detailed budget– statement of work

(including deliverables & reports)

– a short narrative as to why you selected the subcontractor

– as well as a cost/price analysis



Step 2

Enter your budget



Step 3

Upload: a short narrative as to why you selected the subcontractor

as well as a cost/price analysis



Step 4

Upon final submission in the on-line system an email will be sent to the Subagreements Team Notifications on progress will be sent via the ICOL system.



Old Process FlowP

D/

PI

PD

/P

IA

/PA

/P

Su

bSu

b

PI reviews

Enter into PeopleSoft

Approve

Yes

Back to Subfor more detail

Check Issued

No

Generates Invoice

Dep

t.A

dmi

n

Dep

t.A

dmi

n

receives invoice

Process Complete Payment Received

“Firsthand Knowledge”



New Process FlowP

D/

PI

PD

/P

IA

/PA

/P

Su

bSu

b

PI reviews

Enter into PeopleSoft

Approve

Yes

Back to Subfor more detail

Check Issued

No“Firsthand Knowledge”

Generates Invoice

Dep

t.A

dmi

n

Dep

t.A

dmi

n

receives invoice

Process Complete Payment Received

OS

POS

P

Receive InvoiceCode Invoice &

post on ImageNow

Coding and scanning includes adding meta tags such as; PI, Fund #, and Amount

Update on ImageNow

Add Meta Data on ImageNow



A framework for compliance and expectation

Reports = Document program progress

Invoices = Request supporting material

Budgets = Evaluate progress

Tracking = Oversight (IRB reviews)

Supervise = Understand where and why

Authorization = Collect documentation



Reports and Invoices

Reviewing subrecipient reports and billings, and following-up on areas of concern– Does the billing/invoices amount accurately

represent the amount of scientific data or progress by the sub?

– Is there sufficient supporting documentation to determine if the expense on the invoice are allowable? (Think 3 years down the road)



Budget

Monitoring subrecipient budgets– Is the sub spending the money too quickly?

Will they run out before the work is complete?– Is the sub having

trouble getting started on the project?



Tracking

Tracking to ensure timely submission of required reports– WebWise:



Authorization documentations:

Know ahead of time what type of communication and how to authorization occurs– Signature Authority: who has it?– PI approval documentation

Document…



Short Break



Verification

Roles, Responsibilities & RiskOffice of Sponsored Office of Sponsored Programs (OSP):Programs (OSP): ensuring that the Institute’s subrecipient monitoring procedures are compliant with regulations. Unit Financial Officers Unit Financial Officers (Departmental (Departmental Administrators):Administrators): assist PI’s in carrying out their responsibilities. Principal Investigators Principal Investigators (PI)(PI):: is ultimately responsible

Documentation

Regulations



Roles, Responsibilities & RiskOffice of Sponsored Programs (OSP): ensuring that the Institute’s subrecipient monitoring procedures are compliant with federal and other applicable regulations this include:Compliance requirementsFlow-down provision: Prime to subDebarred or suspended checkAudit certification letters from subrecipients



Roles, Responsibilities & RiskUnit Financial Officers (Departmental Administrators): assist PI’s in carrying out their subrecipient monitoring responsibilities includes:ReviewingInvoice Approve & to A/PExcessive charges request clarificationMaintain InvoicesMaintain documentation of monitoring effortsVerify or confirm cost share (if required) has been met by Sub



Roles, Responsibilities & RiskPrincipal Investigators (PI): management of federally funded projects includes:MonitorReviewVerifyingApprovingAllowable, Allocable, Reasonable, & Period of PerformanceKeep records of notes of phone conversations and email correspondence



Roles, Responsibilities & Risk

4 Subrecipients Classes 1. Not-for-Profit: Large

awards >$500,000

2. Not-for-Profit: Mid-sized awards $100,000 – $500,000

3. For-Profit Entities

4. Non US-based entities



Risk Factors

Size of the sub-award ($50,000 vs. $5,000,000)Percentage of pass-throughComplexity of sub-awardSub-recipient’s experience– Administering– Deliverables

Prior monitoring and audit resultsSingle year vs. multiyear sub-awardType of entity– OMB-A-133 or not– Non-profit/Profit– Domestic/Foreign



Know your sub-awardeeSub-recipient monitoring begins at proposal

development

An understanding of the capabilities of your sub-awardee can, and should drive your budget development and monitoring plan

Assess the awardee

Assess the level of expertise (Institution/College/Department)

– Review what can be monitored– Tailor the agreement



Know your sub-awardeeKnow your sub-awardee– Review the latest A133 audit– Assess the SOP for Documentation– IRB (document IRB oversight and that it remains current )– IACUC– Effort reporting – overload payments– Committed Cost Share– F&A (not everyone uses MTDC)– Assess your risk

Set your expectations and reporting requirements– Delineate your deliverables – put them in the sub-award

contract (request supporting documentation for each invoice)



Financial ReportsRecommend quarterly financial reports with business official signature– Makes sure everybody is watching– Triggers and focuses review in manageable bites– Reconciles invoices / payments / receipt of

payment (facilitates annual report)

– Include progress on cost share

– Remember to document a relationship between programmatic progress and financial expenditures



Keeping Risk In Mind…

What is your purpose of sub-recipient monitoring?– Compliance– Need for technical assistance– Follow-up

What is the associated risk of noncompliance– Experience of your sub-recipient



Risk Exercise


Subrecipient Monitoring Overview & Closing

InitiationPlanning

& SubmissionClosing/

Transition

Proposal Development

& SOW

Eligible Subrecipient or vendors

ReviewingInvoice Approve

Deliverables

Final Report & Deliverables

Proposal Routing Sheet

Set up infrastructure for project and

monitoring

Maintain Scanned Invoices & documentation – sending

to A/P

Archivedocumentation

for Audit

Verify Institutional

Requirements

Submit ProposalDebarred

& Suspension Check

Maintain Scanned Invoices Compliance Requirements

Audit Letters

CloseoutProcedures

PD

/PI

Dep

t.O

SP

RISK Assessment & MitigationAll

Execution Monitor

Iterative: test & evaluation

SOW•Requirements•Milestones•Deploy



Thank you

Documents

Office of Sponsored Programs All rights reserved GTRC The New OSP Request for Subaward & Subrecipient Monitoring Course Dana Simpson: Contracting Officer,