Help us learn about you◦ BBI’s organizational structure ◦ Folks’ roles/responsibilities◦ How you operate at various stages of the lifecycle
Review Sponsored Project lifecycle & guiding principles
Strategize on how to more efficiently work together to◦ Facilitate achieving the award’s goals & objectives while
adhering to sponsor’s requirements & SU policies / practices
Today’s goals… Get us all on the same page…
Spending Federal Dollars◦ Comes with strings attached◦ Want to avoid knots or the noose
Why??◦ Fed’s expectations: ??
At proposal submission – SU agrees to follow award’s terms and conditions including following SU policies/procedures, reporting requirements & the cost principles, which require that costs are:
Allowable – under terms of award and SU or entity policy Allocable – can reasonably determine benefit received by award and
cost proportional to benefit Reasonable – prudent person test (necessary) Consistently treated – either direct cost or indirect cost
Guiding principles
BBI’s organizational structure
Folks roles/responsibilities
How you operate at various stages of the lifecycle including communications & information management
About BBI
Find FOA ApplyNegotiate
Award & Set up
Manage Award
Close-out & Repeat or
Recompete
The Sponsored Project LifecycleTransparency & Accountability to Avoid Fraud, Waste & Abuse
Find Funding Opportunities
BBI’s activities OSP
How & Who?
Go / no go process
Who notifies OSP (MMcB) about plans & when ?
COS
IRIS
Grants.gov / fbo.gov
Distribute to BBI leadership
Find FOA ApplyNegotiate
Award & Set Up
Manage Award
Close-out & Repeat or
Recompete
The Sponsored Project LifecycleTransparency & Accountability to Avoid Fraud, Waste & Abuse
It’s a go – you’re going to apply
BBI OSP
Who’s responsible for what?
Needs◦ FOA information ASAP
URL PI & team Partners (non-SU)
Ltr of Com’tnt AOR SOW Budget required format
◦ Time to review & authorize 7 b-days: budget 3 b-days: complete app
◦ Service guidelines
You’re Applying….
BBI OSP
Internal Review◦ What is goal of project?◦ Who has expertise?
BBI? Collaborators?? What is each group
doing? Cost? Parts and whole
◦ Info Management Version control Naming conventions
Reviews ◦ Application adherence
◦ IRR congruence
◦ Confirmation of 3rd party approvals
◦ FAR exceptions
◦ Lots of other stuff…
Submits
Decision to be made at proposal stage.◦ Not all treated the same in terms of F&A
◦ Regardless of Type of 3rd party relationship – In advance, have a SOW or at a minimum a clear understanding of
what they will do for you
◦ Characteristics of subrecipients, Vendors (purchased services) or consultants Lots of detailed information
Subrecipient ◦ Responsible for work and award performance◦ Subject to certifications/assurances (Human Subjects)
If at SU – would be PI or other key personnel
Subrecipient / Vendor / Consultant
Vendor◦ Services provided are core to their mission◦ Provide same services for many customers ◦ Price published or same rate for similar customers
May be non-profit organization Caveat – IHE’s procedures may impact agreement type
Consultant◦ Individual who provides advice or discrete service modest
scale A type of vendor in terms of award T&C (e.g., not subject to human
subjects assurances but may be subject to confidentiality provisions.)
Is “work for hire”◦ Use ‘worksheet for non-SU employees”
Subrecipient / Vendor / Consultant
Made up of many parts…
Much of our focus is on:
◦ Project plan – narrative, description etc Including Statement of Work (SOW)
◦ Budget
◦ Budget justification
Reminder - Application…
SOW vs Budget - two sides same coin -
BudgetSOWSOW
Budget is financial expression of statement of work (SOW).Work drives costs; each collaborator should define & “own” SOW
SOWs from each individual component
SUSub#1Sub#2Sub#3PurchSvc#1PurchSvc#2Cons't#1Cons't#2
Project Work Plan comprises…
Find FOA ApplyNegotiate &
Set Up Award
Manage Award
Close-out & Repeat or
Recompete
The Sponsored Project LifecycleTransparency & Accountability to Avoid Fraud, Waste & Abuse
OSP responsibilities / tasks
BBI’s responsibilities / tasks
Subrecipient process under award management
Award Negotiation & Set Up
Grants / Contracts–
◦ Standard Terms & Conditions or Troublesome clauses (reviewed and identified at proposal submission)
◦ Where FAR exceptions accepted?
◦ Was there a modification to submitted budget or work plan? Adjust key personnel effort Modify scope of work Allowable costs?
Negotiate Award - OSP
Compliance check◦ Human subjects congruence◦ COI all folks◦ Debarment/suspension◦ IRR◦ etc
Award Set up - OSP
Common omissions delays… No Internal Routing and Review form
No current COI for key personnel
Human subjects protocols pending◦ Allocate $$ (easier if clear up front)
Human Subjects Not Human Subjects
Allocation of award to multiple SU units not clear
OSP OSA for Chartstring creation (new award)
OSP BBI PI, budget manager & project manager Award package: chartstring, T&C etc. New – OSP will confirm with BBI that any 3rd party
partners are the same as in proposal OSP will request institutional profile & conduct risk
assessment
After negotiation & compliance reviews… Award Set up - OSP
When GRANT agreement isn’t in hand – request as soon as known and practical
Contracts: only when we know start date and it’s not effective dated; high risk
Same compliance reviews as for awards
Not allowed◦ Subrecipient costs◦ Human subjects costs without congruence complete
What about forward funding?
Find FOA ApplyNegotiate
Award& Set Up
Manage Award
Close-out & Repeat or
Recompete
The Sponsored Project Lifecycle Transparency & Accountability to Avoid Fraud, Waste & Abuse
Manage the award - discussion
BBI OSP
Responsibilities◦ PI
◦ Day-to-day
◦ Financial
◦ Subrecipient
◦ Consultants
Information management
Negotiate amendments
Obtain sponsor prior approvals
Facilitate (sub)award administration
Facilitate compliance with SU / sponsor’s policies, T&C
Review all expected obligations upon receipt of award materials◦ ALL BBI personnel effort: review / revise upon receipt of every new
award and anticipated award.◦ 3rd party collaborations – plan ahead◦ Standing orders – plan ahead
Avoid confirming invoice attached
Not named folks debarment / suspension (epls.gov)
Review award materials especially terms and conditions to know what you can & can’t do.
DoL & cooperative agreements much less flexibility ◦ You can’t move named personal around at will. ◦ CONSIDER – name only essential folks
Award Mngt: Worth repeating…
Proposal Commitment:
SOWBudget &
Justification
Award –OSP BBI: Same 3rd parties?
BBI: Req 2 Issue & refine/ revise SoW & Budget
OSP: Request Profile & conduct risk assessment
OSP: Develop Subaward,Negotiate,Execute
Set up PO
Manage /monitor subawards
BBI: ProgressApprove $$
OSP: costs, timing, pace
Subaward process Transparency & Accountability to Avoid Fraud, Waste &
Abuse
From risk assessment, develop subaward◦ Cost reimbursable vs fixed price WHY
◦ Reporting requirements
◦ Financial supporting docs etc
Execute subagreement
Create PO in ePro
Set up in SADb
Send subagreement to BBI
Monitor ‘process’
Subrecipient Management - OSP
Managing your Award
Award Management Aid
Manage the (Sub)award – BBI discussion
Common challenges…and the consequences
Collaborators◦ Letters of commitment from authorized rep.
Partner may reject award Certs & Assurances not obtained from subaward delays
◦ Budget / budget justification Financial risk
◦ Statement of work missing or◦ Ambiguous standards of performance◦ Not unique to project
Errors in management “Braiding & Blending” allocobility concerns
Issue New subaward
Modify Existing subaward
Proposed- Subaward materials Transmittal
Deep Dive: Request to
Subaward Db - screenshot
Questions frequently asked of OSP
Why am I not being paid???◦ There is no agreement in place
No agreement – no obligation by SU
◦ No invoice has been received No invoice – no way to pay
Invoice review guidance
Other matters
Continuation…
And a year goes by….
Non-competing continuationsProcess varies by sponsor
BBI OSP
Annual Progress report
Complete ‘continuing application’
HINT: Work with sub’s same time to obtain updated SOWs and budgets for next budget period (~90d out)
Carry over?
Signs as authorized official or AOR, as required.
Reviews /approves budgets
Requests carry over, as applicable
OSP not informed of continuation process
Subaward continuation challenges
◦ Not done in a timely manner
◦ Ambiguous statement of work
◦ SOW similar to other awards
◦ Budget poorly justified with little linkage to SOW
◦ Inadequate budget justification
Baton gets dropped along the way – Communications / info management challenges◦ Agreement execution◦ Invoice management
Potential speed bumps
Formal process to ensure that all University obligations to sponsor have been met.◦ Programmatic
All required reports Invention reports
◦ Financial Final Financial report
Review all documentation Property Reports
◦ Subaward – as above
Close-out
Accepting federal $$ comes with MANY obligations, i.e there are strings attached.
Current administration –◦ Transparency and accountability to avoid Fraud, Waste, and
Abuse
Braiding and blending is not consistent with the allocobility cost principle
You will be audited. ◦ Following regulations, policies & SU procedures; timely actions;
and complete documentation are best protections against questioned costs, embarrassment, loss of reputation etc.
When bad things happen to good people
Late awards to SU◦ Impacts subawards◦ Effort Reporting◦ Cost transfers – too many, and not timely
Debarment & suspension◦ Must be done prior to hiring◦ Sub’s – we ask for certification, but they are
responsible for conducting epls check
Last audit
Effort – personnel compensation and supplemental pay (Extra Service) ◦ Subawardee effort procedures
Travel – especially foreign travel
Recharge Centers
Subrecipient monitoring
Administrative costs
Eligible activities
Future audits (IG work plans / A-133)
Accepting federal $$ brings with it the obligation to be responsible steward of those $$
Efficient and effective practices facilitate stewardship
Strategize / document what can we each do to support this goal…
Summary
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