1The Office of Research Services
The Office of Research Support Services REVISED September 2013
Sponsored Programs at Penn
Proposal Budget Preparation, Budgeting Using PennERA
and Routing & Approval
2The Office of Research Services
The Office of Research Support Services REVISED September 2013
Where Do You Start?
• Gather the Facts – Talk to the Principal Investigator (PI)
• What is the Scope of Work?• Who is the Sponsor?• Where will the work be performed?• Collaborators?• Consultants?
3The Office of Research Services
The Office of Research Support Services REVISED September 2013
Sponsor Guidelines
• Instructions and Contractual Terms• Requests for Proposal/Quote (RFP/RFQ)• Requests for Application (RFA)• Funding Opportunity Announcements (FOAs)• “Unsolicited” Applications• Send sponsor guidelines, instructions,
contractual terms, etc., to Research Services
4The Office of Research Services
The Office of Research Support Services REVISED September 2013
Cover Page
• PI Name• Title • Name of Grantee
– Trustees of the University of Pennsylvania• Period of Performance• Amount Requested • Required Signatures
5The Office of Research Services
The Office of Research Support Services REVISED September 2013
RFProposal • Government generates scope of work via
Notices/Program Announcements.• You respond with how you will accomplish,
budget and time frame.• Contract is usual award document for RFP/RFQ
while a grant/cooperative agreement is usual award document for RFA.
RFQuotationRFApplication
6The Office of Research Services
The Office of Research Support Services REVISED September 2013
Budget preparation is a collaborative effort!
• Principal Investigator:– Should work with the Grants Manager to develop the
budget.– Designates others who might have input, e.g., lab
manager, research coordinator.
7The Office of Research Services
The Office of Research Support Services REVISED September 2013
Reasons for carefully preparing the budget
• Reduces the possibility of significant budget cuts by the sponsor.
• Aids post-award management.• Aids the department in budget planning.• Significant budget changes are interpreted by
sponsors as a change in scope!
8The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget
• Costs requested in proposal budget must:– Be Allowable (Factors used in determining)
• Allocable • Reasonable• Consistently Estimated
– Directly benefit the proposed project
Costs must be necessary for the performance of the award (OMB Circular A-21); SPP #2108, #2110, #2138
9The Office of Research Services
The Office of Research Support Services REVISED September 2013
Regulatory guidance• CAS 501 (app. OMB A21, 48 CFR 9905.501)
– “The purpose of this standard is to ensure that each educational institution's practices used in estimating costs for a proposal are consistent with cost accounting practices used by the educational institution in accumulating and reporting costs.”
10The Office of Research Services
The Office of Research Support Services REVISED September 2013
Other considerations• Sponsor guidelines and limitations
– Salary caps– F&A limitations– Direct cost or total cost limits– Expense category exclusions
• Recover F&A as direct costs from non-governmental sponsors– SPP #2138 Direct Cost Expenditures for Non-Govern
mental Agencies• May be School-specific rules
11The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (Salary)• Salary requests are expressed as % effort or person
months• Plan realistically
– Determine the percent of effort for all personnel needed to conduct the project
– Downward adjustments of effort may need sponsor approval
• Percent of effort=Percent of salary requested– Cost sharing is discouraged– Avoid hourly rates
• Cannot usually charge clerical salaries or administrative costs directly
12The Office of Research Services
The Office of Research Support Services REVISED September 2013
Allowability of clerical and/or administrative staff expense
• Generally part of F&A costs.• Possible exceptions (see OMB A21, Exhibit C):
– Large, complex programs (e.g., Center grants).– Epidemiological studies, clinical trials.– Scheduling seminars/conferences attended by large
numbers of participants.– Individual projects requiring project-specific tasks
such as database management, human and animal protocols, etc.
13The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (Benefits)
• Fringe Benefits are charged as a % of Salary• As of 06/21/13, rates on federally sponsored
projects:– Full-time employees – 31.8%– Part-time employees - 9.7%
• For non-Federal sponsors, add Spouse and Dependent Tuition Benefit (2.2% ) for full-time employees
• Current F&A and benefits rates
14The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (Equipment)• Definition
– “Equipment” costs $5,000 or more per item, and has a useful life of more than 1 year
– Includes computer software that meets this definition (capitalized computer software).• Accounting Policy #1106.0
• Justification– Why is this item necessary to support the science?– When is it necessary?
• Availability– Is the equipment available elsewhere in the
University?• Competitive Bid Requirement
15The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (Office Supplies)
• Generally not treated as direct costs.• Can be allowable if specifically related to the
project. For example:– Specific aim of the project is to create a manual or
other instructional media.– Extensive human subjects data accumulation,
questionnaires, etc., is required.• Must be necessary for conduct of project
– OMB Circular A-21, Exhibit C
16The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (Travel)
• Usually restricted to employees• Domestic• Foreign
– Fly America Act if Federal $$– May require prior approval even if in budget
17The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (Patient Care)
• Defined in rate agreement:“…hospitalization and other fees associated with patient care whether the services are obtained from an owned, related, or third-party hospital or other medical facility…”
• Excluded from MTDC base and F&A calculations.
18The Office of Research Services
The Office of Research Support Services REVISED September 2013
What is not included in patient care?
• Subject reimbursement and travel.• Costs of ancillary tests performed outside the
hospital on a fee-for-service basis.• Costs accumulated in service centers at Penn,
such as in Radiology for research patient care.• Consulting physician fees.• All of the above are “other” or “consultant”
expense.
19The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (Subcontracts)
• Budget, including F&A costs• Copy of F&A rate agreement• Statement of Work (SOW)• Cover page/Letter of Intent with Authorized
Signature• Reps/Certs required by sponsor
20The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (Consultants)• Penn staff usually cannot be included in this
category– If applicable, must coordinate payment through Penn
Payroll Office.• Consultant’s letter of intent and cost
– All costs related to the consultant including travel are usually accumulated in this category.
• Statement of Work– Consortium agreements typically used if consultants are
identified as Key Personnel.
21The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (Other Direct Costs)• Service Center charges• Tuition and Fees (Research Projects)• Post Doctoral Health Insurance• Publication Costs• Protocol Review fees, when appropriate• Rent, when appropriate, but excluded from MTDC.• Animal per diem.• Subject compensation and travel
SPP #2110 Federal Direct Cost Expenditures;SPP #2138 Direct Costs Expenditures for Non-Government Organizations
22The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (F&A Costs)• F&A = Overhead = Indirect Costs
– Pays for many costs that cannot be allocated to a specific project, i.e. utilities, administrative payroll and other support services, etc.
• The “Colleges and Universities Rate Agreement” contains the federally negotiated F&A rates
• F&A usually expressed as a % of a base• Modified Total Direct Cost Base (MTDC)
– Excludes equipment, patient care costs, student tuition, and fees, alterations and renovations, rental of off-site facilities and the portion of each subcontract in excess of $25,000
• Check sponsor guidelines for appropriate base
23The Office of Research Services
The Office of Research Support Services REVISED September 2013
Preparing the Budget (F&A Costs)• Which rate to use?
– Research rates (on- and off-campus) [60% & 26%]– Certain DOD Contracts [62%]– Instruction [57%]– Other Sponsored Activities (on- and off-campus) [36% &
26%]• Examples: health or community service projects,
seminars, conferences, exhibitions, lecture programs– Clinical Trials [28% Total Direct Costs (TDC)]– Corporate Contracts [62%]
• Current agreement
24The Office of Research Services
The Office of Research Support Services REVISED September 2013
When is the offsite rate applicable?
• Use this rate whenever activity will occur for 3 months (or 25%) or more at a facility not owned by the University.– Consider preparing a split-rate budget when
appropriate.• Remember that rent can be a direct charge
when using the off-site rate.– Rent is excluded from MTDC and F&A calculations.
25The Office of Research Services
The Office of Research Support Services REVISED September 2013
Don’t overlook• Are there humans involved?
– Subject compensation and travel?– Related patient care costs?– Equate costs proposed to research plan, especially
with the consents.• Are there animals involved?
– Prepare detail cost estimate: include shipping and box charges.
– Animal per diem?– Equate costs proposed to research plan.
26The Office of Research Services
The Office of Research Support Services REVISED September 2013
…and more• Are there large pieces of equipment?
– Installation and set-up included?– Maintenance contracts?– Space available or renovation costs included?
• Provide a quote.• Are there pre- and or post-docs?
– Tuition included?• Excluded from MTDC and F&A.
– Health insurance costs listed?• Not excluded from MTDC.
27The Office of Research Services
The Office of Research Support Services REVISED September 2013
Budget Justification
• Each line item usually requires specific justification.
• Unusual or extraordinary expenses such as equipment, clerical salaries and administrative expenses, may require additional justification.
• Check sponsor guidelines for requirements.
28The Office of Research Services
The Office of Research Support Services REVISED September 2013
Other Considerations
• Specific Sponsor Requirements– NIH modular: ≤$250,000/year– Many non-Federal sponsors may not allow PI salary,
benefits, travel, etc.• Penn Participation Agreement
29The Office of Research Services
The Office of Research Support Services REVISED September 2013
Terms & Conditions• Terms and Conditions
– Must be consistent with University mission of research, education and service
– No bars on publication– University owns and controls intellectual property– Federal regulations appropriate to educational
institutions are used
30The Office of Research Services
The Office of Research Support Services REVISED September 2013
Budgeting Using PennERA Proposal Development (PD)
31The Office of Research Services
The Office of Research Support Services REVISED September 2013
Budgeting Using PennERA PD• Type of budget is automatically
determined by PD during proposal setup.
32The Office of Research Services
The Office of Research Support Services REVISED September 2013
Budgeting Using PennERA PD• Type of budget is automatically
determined by PD during proposal setup.
• Proposal creator answers questions so that PD can select the correct configuration.
33The Office of Research Services
The Office of Research Support Services REVISED September 2013
Sample Budget Configurations Typical setup – detail or simplified entry, S2S or generic records.
Modified for NIH modular budget – detail or simpli-fied entry, only S2S.
Noncompeting records or S2S not requiring a detail budget.
34The Office of Research Services
The Office of Research Support Services REVISED September 2013
Budgeting Using PennERA PD• Two budget entry methods
– Simplified•Minimal data entry•Use if not a Federal system-to-system (S2S) requiring a detail budget
35The Office of Research Services
The Office of Research Support Services REVISED September 2013
Budgeting Using PennERA PD• Two budget entry methods
– Detail•As required by Federal sponsor’s instructions
•Can be used in any PD record
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The Office of Research Support Services REVISED September 2013
• Detail – Personnel Expense
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The Office of Research Support Services REVISED September 2013
• Detail – Personnel Detail Entry
38The Office of Research Services
The Office of Research Support Services REVISED September 2013
• Detail – Non-Personnel Expense
39The Office of Research Services
The Office of Research Support Services REVISED September 2013
• Detail – Non-Personnel Detail Entry
40The Office of Research Services
The Office of Research Support Services REVISED September 2013
• Detail – Subcontract Expense
41The Office of Research Services
The Office of Research Support Services REVISED September 2013
Budgeting Using PennERA PD• Complete other sections:
– F&A• Many proposal records calculate F&A automatically
• If manual entry is used, reset to autocalculation if editing budget expense data entry
42The Office of Research Services
The Office of Research Support Services REVISED September 2013
Budgeting Using PennERA PD• Complete other sections:
– Cost Sharing• Observe Penn’s cost-sharing policies
• Complete cost-sharing form– Upload Budget Justification
43The Office of Research Services
The Office of Research Support Services REVISED September 2013
Routing & Submission
44The Office of Research Services
The Office of Research Support Services REVISED September 2013
PI and BA Submit Proposal• PI and Business Administrator (BA)
have completed all components in PD• Participation Agreement signed and
filed in department• Upload internal documents (e.g., subaccount
worksheet)• PI completes certification• BA completes e-transmittal form• Record submitted to routing path for internal review
45The Office of Research Services
The Office of Research Support Services REVISED September 2013
• What’s a routing path?
…and…
46The Office of Research Services
The Office of Research Support Services REVISED September 2013
• What’s a routing path?…and final step…
• Approvers notified by e-mail message when previous reviewer approves the proposal.
• Only one approval is required per step.
47The Office of Research Services
The Office of Research Support Services REVISED September 2013
Research Services Review• Review e-Transmittal Form &
PI certification for Accuracy & Completeness
• Regulatory Issues• Determine Type of Award• F&A Cost Review• Conflict of Interest• Cost Sharing• Terms & Conditions if
applicable• Check for electronic
submission validation issues
48The Office of Research Services
The Office of Research Support Services REVISED September 2013
Purpose of e-Transmittal• The Transmittal Form
– Internal Form• Does not get submitted to sponsor
– Uses• Departments, make commitments & determine that
project is within total program and academic objectives of department
• Deans, determine that project is consistent with the total program objectives of the school and that commitments for project (including any cost sharing/matching funds) are acceptable
• Research Services uses it to create funds; accuracy matters
49The Office of Research Services
The Office of Research Support Services REVISED September 2013
Proposal Routing and Submission• Approvals
– If project includes faculty from multiple schools/departments • Plan for additional time to secure appropriate approvals
– If project includes participation from another institution• Information from the other institution must also be
obtained and presented in the application• Plan for delays
– Electronic proposal submission issues– Administrative support assisting with multiple grant
applications from multiple PI’s– Broken copiers, scanners
50The Office of Research Services
The Office of Research Support Services REVISED September 2013
Proposal Routing and Submission• Applications requiring additional information
(financial reports) require more time• Responses to RFP’s
– Contractual terms sent to Research Services as soon as possible
– Policy requires 5 days• PI’s transferring from another institution should begin
the transfer process as soon as they have accepted a position at Penn
• Observe individual School deadlines
51The Office of Research Services
The Office of Research Support Services REVISED September 2013
Regulatory Issues• IACUC• IRB
• PI Submits Protocol electronically for Human Subject research using the HS-ERA system and for Animals using ARIES.
52The Office of Research Services
The Office of Research Support Services REVISED September 2013
Office of Regulatory Affairs• Administers
– Institutional Review Board (IRB) – Institutional Animal Care and
Use Committee (IACUC)• Provides Research Services
with approval status for all protocols
53The Office of Research Services
The Office of Research Support Services REVISED September 2013
Institutional Review Board• Protects the rights and welfare
of human research subjects• Authorized to approve, require
modifications in, or disapprove all research activities involving human subjects
54The Office of Research Services
The Office of Research Support Services REVISED September 2013
Human SubjectsApproval Requirements & Timelines
• Approval of a human subject protocol for a new application is not required at time of submission – Unless mandated by sponsor – Approval can be “Just-in-Time” for NIH
• Human subject protocol approval and appropriate education certification– Required to be in place prior to the awarding of a new
project
55The Office of Research Services
The Office of Research Support Services REVISED September 2013
Human SubjectsApproval Requirements & Timelines (cont.)
• For non-competing continuations the approval date must not be earlier than one year before the start date for which the progress report is submitted– If the protocol approval date does not meet this
criteria the non-competing application will be delayed
56The Office of Research Services
The Office of Research Support Services REVISED September 2013
Institutional Animal Care and Use Committee (IACUC)
• Reviews and approves the care and use of animals in research
57The Office of Research Services
The Office of Research Support Services REVISED September 2013
Use of AnimalsApproval Requirements & Timelines
• Approval of an animal subject protocol for a new application is not required at time of submission – Unless mandated by sponsor– Approval can be granted “Just-in-Time” for NIH
• Non-competing continuation applications must have a valid approval date at the time of submission
58The Office of Research Services
The Office of Research Support Services REVISED September 2013
Reminders• Electronic Proposal Submission
– All Electronic Submissions are not created equal– Read the Instructions– Does the PI or Institution need to be registered users?– Is the required technology available at the
Department? At ORS? – All electronic applications must be approved by ORS
before submitting to sponsor even if a paper copy with signatures is required after electronic submission.
SPP #2102 Approval of Proposals
59The Office of Research Services
The Office of Research Support Services REVISED September 2013
Reminders continued…• Meet the specifications of
the announcement • Make it easy for the
reviewers to see that you have done so
• Awards are made to the Institution
• Only Research Services is authorized to sign on behalf of the University
60The Office of Research Services
The Office of Research Support Services REVISED September 2013
Questions???
61The Office of Research Services
The Office of Research Support Services REVISED September 2013
Award Acceptance and Account Set-Up
Sponsored Programs at Penn
62The Office of Research Services
The Office of Research Support Services REVISED September 2013
What is a Notice of Award (NOA)?
• A notice of grant award - also referred to as notice, NOGA, NGA, sponsor notice, contract or award letter - is an official notification from a sponsor indicating that a proposal has been funded.
• Notice of grant awards are typically received by the Office of Research Services [Pre-award offices], although on occasion a PI may be notified directly.
63The Office of Research Services
The Office of Research Support Services REVISED September 2013
What is Contained in a Notice of Award
• PI Name• Dates of Performance
– Current budget period– Total project period
• Dollars– Direct, F&A– Current, project total
• Cost Sharing• Contact information
• General & Special T&C
– Use of Animals/Human Subjects
– Use of Interest Income– Use of Program Income
• Reporting requirements– Programmatic– Financial– Property– Invention
64The Office of Research Services
The Office of Research Support Services REVISED September 2013
Review and Negotiation• ORS Pre-Award and Corporate Contracts staff review
sponsor terms and conditions for compliance with University Policy.
• Non-standard terms may require negotiation or other measures to harmonize with University Policy.
• Selected examples:– Intellectual Property and Tangible Research Policy– Publication– Financial Reporting Requirements– Governing Law– F&A rate (See SPP 2116 Recovery of F&A Costs)
65The Office of Research Services
The Office of Research Support Services REVISED September 2013
Review and NegotiationConsiderations Specific to Corporate Contracts:Expectations of corporate sponsors different from
expectations of public sector sponsors:
Ownership of data and other intellectual output; Confidentiality of work for which sponsor is paying; Control over publication of research; Responsibility/liability for harm that may arise from
research or use of research output’ For clinical trials, rapid, frequently competitive, activation
of protocols.
66The Office of Research Services
The Office of Research Support Services REVISED September 2013
Review and Negotiation Considerations Specific to Corporate Contracts: Internal Review Process Adapted to Accommodate Projects
Funded by Corporate Sponsors:
Agreements to be forwarded to Corporate Contracts for negotiation as soon as sponsor is willing to negotiate/final budget; IRB/IACUC submission not required;
Only items necessary for negotiation need to be forwarded; See eform in Internal Documents in Penn ERA for step-by-step
instructions for this parallel review process.
67The Office of Research Services
The Office of Research Support Services REVISED September 2013
Award example - NIHNOA Section I:• Award Data & Fiscal Information
– Summary of totals for current and future years– Fiscal year of award– Indicates whether an unobligated balance has been
applied to the award amount
NOA Section II:– Grant Payment Information– OIG Hotline Information
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The Office of Research Support Services REVISED September 2013
Award example - NIHNOA Section III: Standard Terms & Conditions• Grant program legislation and regulations• Restrictions on the expenditure of funds in appropriation acts• 45 CFR 74 or 92 as applicable• NIH Grants Policy Statement• Carryover—automatic or prior approval• Included/excluded from Streamlined Noncompeting Award
Process (SNAP)• FDP Institutions noted• FFATA/ARRA • Program Income
69The Office of Research Services
The Office of Research Support Services REVISED September 2013
Award example - NIH• NOA Section IV: Specific Terms and Conditions
– Revisions– Cooperative Agreement– Restrictive terms– Information items– Staff Contact Information– Spreadsheet Summary
70The Office of Research Services
The Office of Research Support Services REVISED September 2013
Exercise• What is the name of the sponsor?• What is the name of Penn’s PI?• Is your award a grant or contract?• Is your award cost-reimbursable or fixed-price per
patient?• What is the first year budget period?• What is the entire project period?• What is the dollar amount obligated under this award?• Are there any subcontracts? • Will PHS-FITS be required?• Bonus: identify 1 or more specific term and condition.
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The Office of Research Support Services REVISED September 2013
Award Example - Foundation• Award layout varies by sponsor
• NOA often references terms and conditions not explicitly named
72The Office of Research Services
The Office of Research Support Services REVISED September 2013
Exercise• What is the name of the sponsor?• What is the name of Penn’s PI?• Is your award a grant or contract?• Is your award cost-reimbursable or fixed-price per
patient?• What is the first year budget period?• What is the entire project period?• What is the dollar amount obligated under this award?• Are there any subcontracts? • Will PHS-FITS be required?• Bonus: identify 1 or more specific term and condition.
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The Office of Research Support Services REVISED September 2013
Account Set-Up
74The Office of Research Services
The Office of Research Support Services REVISED September 2013
Account Set-Up - WorkflowNotice of Award
(NOA)Received and
Negotiation completeFCOI Compliance verified
Fund AttributesFund Parents
Special BudgetsAccount Segments
Assigned in PennERA & Sent to GL
Fund & Legacy Number Created
in BEN Financials & Sentto PennERA
AIS is GeneratedAward Notice Uploaded
in PennERA
Status Changed To AwardFrom Pending, FuturePending, Advance Account,or Account Continuation10 Business Days
75The Office of Research Services
The Office of Research Support Services REVISED September 2013
Workflow• Electronic process for imaging awards and updating
PennERA– Applies to changes to records that result in AIS
• Several steps and roles– Document enters imaging system– Package created and assigned to AD/CA for handling– AD/CA creates account setup summary for package and
sends to Operations– Operations updates award, adds package to PennERA
• Hurdles:– Is PHS-FITS necessary? Is it complete?– Is there a Non-Competing Continuation on file?– Is there inconsistency between the package and record?– Is there a Cost-Share form to be signed?
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The Office of Research Support Services REVISED September 2013
Funds and Accounts• New Funds are created for each year of the award when
carryover of money from one year to the next must be approved by the Sponsor
• New funds are also required when the F&A changes from one segment to another
• New funds may be required if the funding mechanism changes at the sponsor
• Subaccounts are to be requested on the subaccount worksheet
77The Office of Research Services
The Office of Research Support Services REVISED September 2013
Receiving the Award and the Account Information
Sheet (AIS)
AIS is issued online. NOAs are uploaded in the Attachments tab
in PennERA as part of Workflow.For help: [email protected]
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The Office of Research Support Services REVISED September 2013
Review the Award• AIS is not a substitute for award• PI is responsible for all terms• Review terms and conditions of award• Sponsor guidelines• Restrictions• Scientific reporting specifications
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The Office of Research Support Services REVISED September 2013
Review the AIS• Ensure Account End Dates Accurate (budget end or
project end?)• Ensure Award on AIS matches Award on NOGA• Ensure FDP and/or SNAP• Ensure accuracy of F&A rate• Ensure proper PI name and Org#• If the AIS is for a continuation year, always check
for budget periods funded with prior unobligated funds.
• If errors occur, email [email protected]
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The Office of Research Support Services REVISED September 2013
Advance Accounts• What is an Advance Account?
– Use when high probability of award– Allows you to put charges on proper account
• Avoid journal entries and payroll reallocations– Use with pre-award costs under expanded authorities– Easy to request
• ORS Web page has link to Advance Account Request– http://www.upenn.edu/researchservices/pdfs/advance.pdf– PSOM-Advance Accounts are approved and setup by ORSS– All other schools - forward request to ORS Pre-Award
81The Office of Research Services
The Office of Research Support Services REVISED September 2013
Advance Accounts (cont.)• Risks
– Award may not materialize – Start date may be delayed – Not all sponsors allow “Pre-award”
expenditures• Establish follow-up routine
– Has award materialized?– Is something holding it up?– 3 month limit on advance accounts
82The Office of Research Services
The Office of Research Support Services REVISED September 2013
Subaward Process• BA/PI prepares subaward request form
http://www.upenn.edu/researchservices/subawards.html Complete package sent as pdf email to [email protected]
• ORS completes subrecipient monitoring, prepares subaward & sends to subrecipient– Subrecipient signs & returns
• ORS sends email notification to BA that the subaward is fully executed– Signed agreement uploaded to PennERA record
• BA sets up Purchase Order• Subaward activity from request to execution noted in PennERA record activity log.
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The Office of Research Support Services REVISED September 2013
Subrecipient Monitoring• A-133 report or audited financial
statements required annually
• Current F&A rate agreement
• Risk Assessment – results indicate appropriate subcontract terms and conditions
84The Office of Research Services
The Office of Research Support Services REVISED September 2013
Questions???