subawards and the uniform guidance research reps meeting 17 march 2015

Subawards and the Uniform Guidance

Research Reps Meeting 17 March 2015

Introduction

• Uniform Guidance requires Pass Through Entities [PTEs] to develop Subrecipient Plans

• At UWM, divided into four phases

PROPOSAL DEVELOPMENT

AND SUBMISSION

SUBAWARD IMPLEMENTATI

ON

PROJECT PERFORMANCE

AWARD CLOSEOUT

Overview• Subrecipients versus Contractors

– Subrecipients include those entities that• Have responsibility for programmatic decision-making• Measures performance in related to the prime award• Funds and carries out its own programs• Requires unique expertise of subrecipient personnel• May be included as co-authors or publish their own work• Perform work with human subjects or animals

– Contractors include those entities that• Provide goods and services within the normal scope of operations• Provides “off the shelf” goods/services to many different purchasers• Operate in a competitive environment• Provides services that are repetitive in nature• Assumes the risk if performance is more costly and/or time consuming than expected

• Subcontractor Selection Remains the PI’s Responsibility

Proposal Development and Submission

• Information Requested from Subrecipients– Scope of Work– Budget/Budget Justification– Letter of Commitment – De Minimis Rate Agreement (if no negotiated F&A

Rate Agreement)

Subaward Implementation

• UWM has developed questionnaires for subrecipients to complete at time of award

• Data is used to determine the type and structure of the subaward agreement

• OSP will be responsible for obtaining info from subrecipient and developing the subaward agreement

Subrecipient Monitoring• Data from the questionnaire (at time of award and

annually) determines monitoring strategies and are included in the Subaward Agreement. May request:– More frequent invoicing – Information on Single Audit Findings – More frequent technical reporting– Provide training/technical assistance to subrecipient

• Additional Review during Invoice – Ensure “the science matches the spending”

Award Closeout

• Subrecipients must provide their final invoices and account for real/intellectual property within 45 or 60 days from the end of the project

• Subrecipient responsible for notifying UWM immediately if costs are later disallowed during an audit

Conclusion

• Subaward Guides forthcoming:– UWM Principal Investigators – Subrecipients

• Questions?– Send to or-osp-uniformguidance@uwm.edu