Subaward Basics and Subrecipient Monitoring Pilot · Subrecipient Basics and Monitoring Offered by: ... monitoring and the processing of subrecipient invoices. ... improvement of

Welcome to

Subrecipient Basics

and

Monitoring

Offered by

Office of Sponsored Projects (OSP)

1

Session Agenda

bull Course Objectives

bull Course Overview

bull Definitions

bull SubrecipientVendor Determination

bull Preparing a Proposal That Includes a Subrecipient

bull Preparing Negotiating and Executing Subawards

bull Subaward Setup Process

bull Subrecipient Invoicing Process

bull Subrecipient Monitoring

bull Closeout of Subawards

bull Retention of Subrecipient Records

bull Course Takeaways

bull Quiz

2

Course Objectives

As a result of attending this course you will

Understand the roles and responsibilities of individuals involved in the subaward process

Be able to differentiate between a subrecipient and a vendor relationship

Gain a greater awareness and understanding of Yalersquos policies and procedures related to subrecipients

Learn the requirements and expectations for subrecipient monitoring and the processing of subrecipient invoices

Know where to locate resources to assist in the subaward process

3

Course Overview

Pre-award

SubrecipientVendor Determination

Preparing a Proposal That Includes a Subrecipient

Preparing Negotiating and Executing Subawards

Subaward Setup Process

Post-award

Processing Subrecipient Invoices

Subrecipient Monitoring

Closeout of Subawards

Subrecipient Records Retention

4

Definitions

Research

A systematic investigation including design development systems or methods improvement of prototypes new processes testing and evaluation designed to develop or contribute to generalizable knowledge Research may include patient-oriented research including epidemiologic and behavioral studies outcomes research and health services research conducted with human subjects (or on material of human origin such as tissues specimens and cognitive phenomena)

Subrecipient (also referred to as a subawardee or subcontractor or subgrantee)

A legal entity that receives a subaward from Yale under an award made to Yale

bull Accountable to Yale for the use of the funds in carrying out a portion of the programmatic effort under Yalersquos award

Subaward (also referred to as a subgrant subcontract or subagreement)

A legal instrument between Yale and a legal entity in which Yale provides funds (or property in lieu of funds) to the legal entity to perform a substantive portion of Yalersquos award

5

Definitions


Activities undertaken to review the financial status management controls and performance of a subrecipient in order to mitigate risk when contracting with a subrecipient organization

Vendor

A dealer distributor merchant or other seller providing goods or services during normal business operations and that are required for the conduct of a sponsored project

bull Operates in a competitive environment

6


7

Office of Sponsored Projects (Pre-Award)(OSP)

bull Provides guidance to PI and DBO on subrecipient versus vendor determination

bull Reviews and approves required subrecipient documents

Department Business OfficeAdministrator

(DBO)

bull Assists PI with the subrecipientvendor determination

bull Ensures that all required subrecipient documentation is sent to OSP Pre-Award for review

Principal Investigator (PI)

bull Identifies work that needs to be done by a non-Yale entity

bull Consults with Office of Sponsored Projects (OSP) and DBO to determine the appropriate relationship

SubrecipientVendor DeterminationRoles amp Responsibilities

8


Subrecipient Considerations

bull Carries out research authorized by Yalersquos award

bull Measures performance against the objectives of Yalersquos award

bull Has responsibility for programmatic decision-making

bull Receives funds to carry out its own program

bull Exercises considerable discretionary judgment

bull Provides matching funds or cost sharing as required

Vendor Considerations

bull Provides goods or services for the direct benefit of an award

bull Sells similar goods or services as part of its normal business operations


bull Provides services of a repetitive nature or goods of a commonly available kind

bull Provides goods or services that are ancillary to the operation of the prime award program

Subrecipient Initiation Execution Monitoring and Closeout on Sponsored Projects - Procedure 1307 PR01

httphttpyouryaleedupolicies-proceduresprocedures1307-pr01-monitoring-subrecipient-activity-associated-sponsored9


Other Considerations

bull There is a responsible individual at the identified entity

Subrecipient

bull The entity is free to decide how to carry out the activities requested of it

Subrecipient

bull Publications are anticipated

Subrecipient

bull There is a potential that patentable or copyrightable technology will be created or reduced to practice by the entityrsquos PI

Subrecipient

bull The activity to be performed is a series of repetitive tests or activities requiring little or no discretionary judgment

Vendor10


If a vendor is identified incorrectly as a subrecipient what can happen

bull If on a federal award Yale would only receive FampA costs on the first $25000 of expenses (and should have received full FampA)

bull Unnecessary risk assessment was conducted

bull Unnecessary additional regulatory requirements were imposed on the entity

bull Entity will inappropriately own the work product

If a subrecipient is identified incorrectly as a vendor what can happen

bull If on a federal award the vendor would be assessed FampA costs on the entire amount invoiced rather than the first $25000

bull The entity will not be aware of Federal compliance requirements and flow down provisions

bull The entity will not have any intellectual property (IP) or publication rights

Importance of SubrecipientVendor Determination

11

bull Yalersquos procurement policies regarding proper bidding and sole source requirements may be violated

bull The expenses posted would not be included in the correct expense category for reporting and audit purposes

If either a vendor or subrecipient is misidentified

Case Studies

Subrecipient or Vendor

SubrecipientVendor DeterminationCase Study

Case Study 1

A Yale PI identified a company that is in the business of tracking storing and processing blood specimens These services are necessary for the PI in order for her to conduct her research The activities carried out by the company include

bull Sending out blood shipping kits to genetic research centers

bull Receiving blood from the genetic research centers

bull Transferring DNA to the sponsor

Question Are these the type of activities of a subrecipient or a vendor

13

SubrecipientVendor DeterminationCase Study 1 (cont)Answer Vendor

Whybull Providing a service

bull No responsibility for programmatic decision making

bull Little or no discretionary judgment exercised

bull Similar services provided to many different purchasers within its normal business operations

bull No publications expected

bull No patentable or copyrightable technology expected

bull No rights to intellectual property involved

What should the proposal preparer do

bull Receive a quote from the company and complete a sole source justification if necessary

bull Budget for the servicesgoods and apply the full FampA rate in the proposal

14


Case Study 2

A Yale PI identified an offsite lab that will help him complete the Specific Aims of his research award The labrsquos scope of work includes the following

bull Lab will conduct experiments focused on examining the structure processing and function of a plasma enzyme

bull Yale will require a technical report that includes evaluations of the experiments and conclusions

bull Lab PI will publish articles in a scientific journal with Yale PI

Question Are these the activities of a subrecipient or a vendor

15

SubrecipientVendor DeterminationCase Study 2 Contrsquod

Answer Subrecipient

Why

bull Performance measured against the objectives of the award In this case it is against the Specific Aims of the proposal

bull Responsible for programmatic decision making

bull Rights to its intellectual property


bull Budget the Lab as a subrecipient in the proposal and apply the FampA rate appropriately Secure a completed Subrecipient Compliance Information (SIC) form and related subrecipient proposal documents

16

17


bull Reviews subrecipientrsquos documentsbull For NSF PHS and PHS-like sponsors

verifies COI compliancebull Reviews approves and submits

completed Yale proposal to sponsor

Department Business OfficeAdministrator (DBO)

bull Assists PI with the completion of all Yale and sponsor required forms

bull Ensures all required subrecipient documentation (SIC) is complete and sent to OSP Pre-Award


bull Determines work and deliverables required of the subrecipient

bull Ensures subrecipient submits all Yale and sponsor required forms

Preparing a Proposal that Includes a SubrecipientRoles amp Responsibilities

18

Preparing a Proposal that Includes a Subrecipient

Procedure 1307PR01 Subrecipient Initiation Execution Monitoring and Closeout on Sponsored Projects

httpyouryaleedupolicies-proceduresprocedures1307-pr01-monitoring-subrecipient-activity-associated-sponsored

Subrecipient Information amp Compliance (SIC) Form httphttpyouryaleedupolicies-proceduresforms1304-fr03-app-subrecipient-information-and-compliance-form

Conflict of Interest and Subrecipients What you need to know httpyouryaleeduresearch-supportconflict-interestinformation-revised-phs-coi-regulations

Outgoing Subs (Yale is Prime)-Federal Sponsor Checklist amp Nonfederal Sponsor Checklist httpyouryaleeduresearch-supportoffice-sponsored-projectsresources

19

Required Subrecipient Documents

bull Complete Subrecipient Information amp Compliance (SIC) Form

bull Subrecipient StatementScope of Work (SOW)

bull Subrecipient Budget and Budget Justification

Subrecipient FampA Rate AgreementNote If an organization does not have a federally negotiated FampA rate a de minimis rate

of 10 of MTDC must be included in the subrecipientrsquos budget

Note FampA costs under grants to foreign and international organizations will be funded at a

rate of 8 percent of modified total direct costs

bull Additional sponsor specific requirements may require

Biosketches Current and Pending or Support Page consortia andor proposal endorsement letter etc

20

Office of Sponsored Projects (Pre-Award)bull Verifies subrecipient compliance with

sponsorYale requirementsbull Conducts a risk assessment with OSP Post-

Award to determine risk of doing business with the subrecipient

bull Identifies special terms and conditions to mitigate risk of working with subrecipient

bull Prepares negotiates and executes subawardsbull Begins the set-up of the subaward record in SMSbull Notifies OSP Post-Award to complete SMS set-

up


bull Works with OSP Pre-Award to help resolve subrecipient issues

bull Works in collaboration with PI to review and approve draft subaward

bull Works to obtain from subrecipient all remaining required information documents and certifications which may include IRBIACUC protocol approval certification that the sub adopted its own PHS FCOI policy FampA Rate Agreement

Principal Investigator

(PI)

bull Determines frequency and scope of progress reports (but no less frequent than is required by Yalersquos sponsor) and informs OSP Pre-Award to insert this information into subaward

bull Reviews and approves draft subaward

Preparing Negotiating and Executing Subawards Roles and Responsibilities

21

Office of Sponsored Projects (Post-Award)

bull Develops risk mitigation strategy as necessary based on results of GCA risk analysis

bull Completes Subrecipient Monitoring System (SMS) set-up

Note For purposes of award set-up and payment in Yale systems a subrecipient is referred to as a vendor

Vendor Set-up for a New Subrecipient

bull OSP Pre-Award notifies DBO to send a vendor set-up request form to the Vendor Compliance Unit

bull DBO completes the vendor set-up request form

bull DBO obtains completed W-8Ben and T-100 if the subrecipient is a foreign entity

bull DBO sends completed forms to the Vendor Compliance Unit (VCU) for processing and retention in the Vendor Database files

Before issuing a subawardhellip


Note VCU checks for suspension and debarment status prior to the issuance of a subaward A debarment flag will prevent setup of anew vendor in the Vendor Database VCU will contact GCA in such situations

Vendor Setup Request Form httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request22


bull OSP Pre-Award performs a risk assessment of the subrecipient

bull In a high risk situation OSP Pre and Post-Award work in collaboration with the PI and DBO to develop a risk mitigation plan in consultation with the University Research Compliance Officer as warranted

bull OSP Pre-Award prepares appropriate subaward based on Yalersquos award and provides to DBO and PI for review and approval

bull The DBO and PI should pay particular attention to the following terms and conditions (any suggested changes requires OSP approval)

bull Technical program reporting requirements

bull Period of performance and termination

bull Financial billing and payment

bull Ownership of intellectual property and data

bull Special terms and conditions to mitigate risk

Before issuing a subawardhellip (cont)

23


Subaward Negotiations

bull It is not uncommon for subrecipients to have questions or request changes to a subaward

Common questions or negotiation issues include

Reporting requirements

Financial terms and conditions

Intellectual property rights

IndemnificationLiability

bull OSP Pre-Award negotiates the subaward on behalf of the University

24


OSP Pre-Award Responsibilities

bull Uploads a copy of the fully executed subaward into IRESrsquo PT module

OSP Post-Award Responsibilities

bull Completes the Subaward Management System (SMS) data entry and creates a record in the Oracle Financial System

bull Emails the DBO and PI the following

- Copy of SMS Screenshot Report

- Copy of the fully executed subaward

26

Review the following information (derived from the subaward and SMS report data fields) to ensure accuracy and inclusion

bull Vendor Name (subrecipient name)bull Subcontract Amountbull Direct Cost burden limitbull Subcontract Start Datebull Subcontract End Datebull PTAEObull Subcontract Number (verify same as the SMS Number)

DBO Action Upon Receipt of the Fully Executed Subaward


27

28


(DBO)

bull Reviews and approves invoices for allowability and compliance with the terms and conditions of the subaward

bull Assists PI in reviewing invoices and determining if payments are appropriate for the work performed vis a vis the subrecipientrsquos budget and SOW

bull Submits approved invoices timely retains copies for departmental records (includes W-8 or T-100 for foreign subrecipients)


(PI)

bull Reviews and approves invoices (should be consistent with technicalprogress reports and requirements of the subaward)

bull Assists in the resolution of invoice issuesbull Notifies OSP Pre-Award of any performance

issues to addreduce funding extend performance period or terminate the subaward

Processing Subrecipient InvoicesRoles and Responsibilities

Office of Sponsored Projects (Post Award)(OSP)

bull Resolves financial questions related to invoicesbull Assists departments with AP work list to resolve

invoices that fail validationbull Receives subaward closeout information and

deobligates commitments

29

DBOPI Review and Approval of Invoices

bull 2 CFR Part 200 requires the payment of subrecipient invoices issued under Federal awards to be made within 30 calendar days after receipt of the billing unless the billing is believed to be improper

bull Verify that a signed and fully executed copy of the subaward was setupbull Subrecipient Invoices include

o Subrecipient nameo Date of invoiceo Invoice number or referenceo Period of performance covered by invoiceo Expenditures by major category in sufficient detail to enable comparison to

project budgeto Current period costso Cumulative period costso Subrecipient invoice contact persono Certification of expenses by subrecipient fiscal officer that costs conform to the

conditions and support the performance of work by the subrecipient


30

bull Subrecipient invoices are available through the YSS worklisto DBO receives email notification of YSS worklist items o DBO accesses invoices for review and approval from the YSS worklist

bull PI and DBO ensure that the charges represented on the invoice areo reasonable based upon the technical progress of the project o allowable adheres to the budget and SOW and complies with the

terms and conditions of the subaward

o sufficient information to determine the allowability of the cost

bull If any charges are determined to be potentially unallowable or unreasonable DBO should contact OSP to discuss the concerns and next steps


DBOPI Review and Approval of Invoices (cont)

31


bull PI who has knowledge of the projectrsquos technical progress is required to approve each invoice If the PI decides not to approve a subrecipient invoice the DBO and OSP Pre-Award should be contacted as soon as possible

bull DBO approves the invoice on the YSS worklist

bull DBO signature indicates that a review of the invoice has taken place

bull Invoice contains the following certification language as prescribed by A-81

ldquoBy signing this report I certify to the best of my knowledge and belief that the report is

true complete and accurate and the expenditures disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award I am aware that any false fictitious or fraudulent information or the omission of any material fact may subject me to criminal civil or administrative penalties for fraud false statements false claims or otherwise (US Code Title 18 Section 1001 and Title 31 Sections 3729-3730 and 3801-3812)rdquo


32

Validation failures that will cause invoices to go on hold

33

bull Departmental Worklist

o No subaward number referenced

o PTAEO (Invalid or Expired)

o Invalid subaward number

o Wrong vendor name or vendor site match

o Subaward is inactive or pending

o Incorrect subaward expenditure type

o Invoice Expense Identification Date (EID) outside of subaward performance dates

Note Subaward invoices ldquoon holdrdquo must be cleared in a timely fashion


34

What is subrecipient monitoring

Steps taken to ensure that the subrecipient conducts the research appropriately and expenses incurred are in compliance with the terms and conditions of the subaward

Why is subrecipient monitoring important

bull Ensures compliance with the prime award

bull Ensures compliance with the terms and conditions of the subaward

bull Ensures compliance with A-133 or 2 CFR Part 200 requirements for federal awards

bull Supports Yalersquos compliance with the

o Federal Funding Accountability and Transparency Act (FFATA)


35


Who has a role in the subrecipient monitoring process

Subrecipient monitoring is multifaceted and requires the involvement of the

bull PI ndash Through the review of technicalprogress reports and invoices and identifying concerns

bull DBO ndash Through the review of invoices and requests clarification for excessive or inappropriate charges

bull OSP Pre-Award ndash Through the review of the subrecipient questionnaires the risk assessment development of a risk mitigation plan and ensuring plans are executed

bull OSP Post-Award- By collaborating in the development of a risk mitigation plan conducting desk reviews of invoices and ensuring plans are executed

36


bull Subrecipient monitoring is only performed by OSP

Answer False Monitoring is also performed by the PI and DBO

bull The PIrsquos review and approval of invoices is just a formality

Answer False The PIrsquos approval acknowledges review of progress reports andor satisfactory performance by the subrecipient

bull It is the subrecipientrsquos sole responsibility to ensure all invoiced costs are allowable Yale just processes the invoice for payment

Answer False Yale as prime recipient of the award is ultimately responsible for the subrecipient The DBO should review invoices carefully to ensure all costs are allowable

bull It is Yalersquos responsibility to ensure subrecipients are complying with terms and conditions of the subaward

Answer True The University has responsibility throughout the life of the award to ensure awarded funds are used in compliance with the terms of the award and that performance goals are met

bull Yale provides a higher level of monitoring for high risk subrecipients as it does for lower risk subrecipients

Answer True The frequency and monitoring strategies of the subrecipient are based on the risk assessment and management plan of the organization

Subrecipient Monitoring Questions ndash TrueFalse

37

38


Item Responsibility ActionRequired Documentation

Deliverables Yalersquos PI bull Receipt of TechnicalProgress Reportsbull Receipt of Invention Reports and any other

non-financial reports

Final Invoice Department AdministratorPI

bull Verify all deliverables receivedbull Verify all subaward costs are reported on

FSR Bug 203a bull Approve and submit FSR Bug 203a and

Subaward Reconciliation Form to OSP Post-Award which acknowledges all subaward invoices and deliverables have been received and all subrecipient invoices have been included and are accounted for

bull All cost sharing is separately budgeted and accounted for by the Subrecipient

Subaward Closeout Requirements

39

SubawardAward Closeout Timeline

When Action

60 days before subaward end date If the end date of the subaward comports with the end date of Yalersquos award the PI and DBO should evaluate if a no cost extension (NCE) is necessary for Yale and the subrecipient

45 ndash 60 days after subaward end date Department receives all required reports and final invoice for approval of the PI and DBO for processing and payment

60 - 70 days after subaward end date Reconcile award and subaward invoices Prepare the Subaward Reconciliation Form and submit it with signed FSR BUG 203a Report

70 - 90 days past award expiration OSP Post-Award reviews certifies and submits final financial report to sponsor as well as any other reports or Contract Release Forms (federal contracts only) as appropriate

After completion of all awardsubaward reporting

OSP Post-Award changes subaward status to ldquoinactiverdquo and initiates award closeout process

Note Closeout timelines may vary depending on the requirements of the sponsor (ie Federal pass-through awards state awards and some

non-federal sponsors require final reports within 60 or 45 days after award expiration)

Subaward Closeout Timeline

40

41

Retention of Subrecipient Records

bull Subaward documentation must be retained for the same period as Yalersquos award

o State contracts ndash Usually 3 years from the date of the final payment under the prime contract unless otherwise stated in the contract For example Connecticut Stem Cell awards have a 5 year record retention period

o Most federal and private sponsors require a retention period of 3 years from the date of submission of the final expenditure report unless the terms and conditions of the award state otherwise

How long should award records and documentation be retained by the DBO

Office of General Counsel - Yale Record Retention Schedule httpogcyaleedusitesdefaultfilesSchedule2011-10-04_0xls

Yale University Retention of University Financial Records Policy 1105 httpyouryaleedupolicies-procedurespolicies1105-retention-university-financial-records42

Course Takeaways

A subrecipient is not a vendor and a vendor is not a subrecipient

Vendor relationships are processed through Procurement

All subrecipient proposals must include a completed SIC Form Scope of Work budget and budget justification and any other sponsor requirements prior to submitting the proposal to the sponsor

Subrecipient invoices must be approved by the PI and DBO before Yale can pay them

All parties (PI DBO and OSP) play a role in the subrecipientsubaward process and subrecipient monitoring

If a subrecipient is not performing contact OSP Subawards can be terminated for non-performance and non-compliance

43

Resources

Contact

bull OSP ContactAssignments Matrix

o httpyouryaleeduresearch-supportoffice-sponsored-projectssponsored-projects-contacts


Proposal Preparation

bull Transmittal Summary (TranSum) Form

o httpyouryaleedupolicies-proceduresforms1304-fr03-transmittal-summary-tran-sum-form

bull List of PHS and PHS-like agencies (for COI purposes)

o httpyouryaleeduresearch-supportconflict-interestinformation-revised-phs-coi-regulations

Subaward Set-Up

bull Vendor Setup Request Form 3205FR01

o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request

bull Subrecipient Procedure 1307 PR01

o httpyouryaleedupolicies-proceduresprocedures1307-pr01-monitoring-subrecipient-activity-associated-sponsored

bull W-8Ben and T-100 form for foreign subrecipients

o httpyouryaleedupolicies-proceduresforms3205-fr05-w-8ben-certificate-foreign-status-beneficial-owner-united-states

o httpyouryaleedupolicies-proceduresforms100-t-100-statement-independent-personal-services-performed-yale

o httpwwwirsgovpubirs-pdffw8benpdf

44

Resources

Federal Regulations

bull OMB Circular A-133 Compliance Supplement (Part 3 Section M ndash Subrecipient Monitoring)

o httpwwwwhitehousegovombcircularsa133_compliance_supplement_2013

bull 2 CFR Part 215 (OMB Circular A-110) Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education Hospitals and Other Non-Profit Organizations

o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part215content-detailhtml

bull Federal Acquisition Regulations (FAR) - (For contracts)

o httpsacquisitiongovfar

bull 2 CFR Part 200 (OMB Circular A-81) Uniform Guidance

o httpwwwecfrgovcgi-bintext-idxSID=15d5184c2810c3eef54cd7109663b443ampnode=pt21200amprgn=div5

bull 2 CFR Part 220 (OMB Circular A-21) Cost Principles for Educational Institutions


45

Resources

46

Vendor Information Guidance

bull Contact information

o httpyouryaleeduwork-yalefinance-and-business-operationsprocurementvendor-information

bull Consultant Contracts Information

o httpyouryaleeduwork-yalefinance-and-business-operationsprocurementvendor-informationconsultants-or-professional

bull Policy 3210 Consultants and Professional Services Agreements

o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting

bull Vendor Setup Request Form


University Policy and Procedures

bull Form 1304 FR03A - Subrecipient Information and Compliance (SIC) Form

o httpyouryaleedupolicies-proceduresforms1304-fr03-app-subrecipient-information-and-compliance-form

bull Procedure 1307 PR01 - Monitoring Subrecipient Activity Associated with Sponsored Programs

o httphttpyouryaleedupolicies-proceduresprocedures1307-pr01-monitoring-subrecipient-activity-associated-sponsored

bull Policy 1307 - Subrecipient Monitoring

o httpyouryaleedupolicies-procedurespolicies1307-subrecipient-monitoring

bull Policy 3210 - Consultants and Professional Services Agreements


Click here to access the Quiz

You must take and pass the quiz in order to receive credit for the course

47

Session Agenda

bull Course Objectives

bull Course Overview

bull Definitions

bull SubrecipientVendor Determination

bull Preparing a Proposal That Includes a Subrecipient

bull Preparing Negotiating and Executing Subawards

bull Subaward Setup Process

bull Subrecipient Invoicing Process

bull Subrecipient Monitoring

bull Closeout of Subawards

bull Retention of Subrecipient Records

bull Course Takeaways

bull Quiz

2

Course Objectives







3

Course Overview

Pre-award





Post-award





4

Definitions

Research







5

Definitions



Vendor



6


7





(DBO)







8




















Subrecipient


Subrecipient


Subrecipient


Subrecipient


Vendor10












11




Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

Course Objectives







3

Course Overview

Pre-award





Post-award





4

Definitions

Research







5

Definitions



Vendor



6


7





(DBO)







8




















Subrecipient


Subrecipient


Subrecipient


Subrecipient


Vendor10












11




Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

Course Overview

Pre-award





Post-award





4

Definitions

Research







5

Definitions



Vendor



6


7





(DBO)







8




















Subrecipient


Subrecipient


Subrecipient


Subrecipient


Vendor10












11




Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

Definitions

Research







5

Definitions



Vendor



6


7





(DBO)







8




















Subrecipient


Subrecipient


Subrecipient


Subrecipient


Vendor10












11




Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

Definitions



Vendor



6


7





(DBO)







8




















Subrecipient


Subrecipient


Subrecipient


Subrecipient


Vendor10












11




Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47


7





(DBO)







8




















Subrecipient


Subrecipient


Subrecipient


Subrecipient


Vendor10












11




Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47





(DBO)







8




















Subrecipient


Subrecipient


Subrecipient


Subrecipient


Vendor10












11




Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47




















Subrecipient


Subrecipient


Subrecipient


Subrecipient


Vendor10












11




Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47




Subrecipient


Subrecipient


Subrecipient


Subrecipient


Vendor10












11




Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47












11




Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

Case Studies



Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47


Case Study 1






13












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47












14


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47


Case Study 2






15


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47


Answer Subrecipient

Why






16

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

17












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47












18







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47







19











20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

20






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47






up






(PI)




21

























23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47






















23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47












23










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47










24









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47









26





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47





27

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

28


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47


(DBO)





(PI)









29








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47








30








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47








31









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47









32


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47


33











34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

34










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47










35








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47








36













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47













37

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

38











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47











39


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47


When Action










40

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

41








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47








Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

Course Takeaways







43

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

Resources

Contact









Subaward Set-Up









44

Resources

Federal Regulations











45

Resources

46





















47

Resources

Federal Regulations











45

Resources

46





















47

Resources

46





















47



47