office of sponsored programs all rights reserved gtrc the new osp request for subaward &...
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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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
Overview
Definitions and policies– Georgia Tech’s policies– Subrecipient– Request for Subaward– Vendor– Roles– Responsibilities– Risk– Authorization
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
Georgia Tech’s Responsibility
Georgia Tech is responsible for ensuring that all subrecipients of its sponsored research awards are in compliance with applicable requirements.
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
Georgia Tech’s Guidelines
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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)
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
SOW should include:
Objective or PurposePeriod of PerformanceMilestonesA list of detailed work requirementsWorkload requirementsPersonnel requirementsResources (if any) to be furnished to the subcontractor
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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.
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
Step 2
Enter your budget
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
Step 3
Upload: a short narrative as to why you selected the subcontractor
as well as a cost/price analysis
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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.
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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”
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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)
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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?
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
Tracking
Tracking to ensure timely submission of required reports– WebWise:
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
Authorization documentations:
Know ahead of time what type of communication and how to authorization occurs– Signature Authority: who has it?– PI approval documentation
Document…
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Subrecipient Monitoring
Short Break
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Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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)
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
Risk Exercise
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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
Office of Sponsored ProgramsAll rights reserved GTRC
Subrecipient Monitoring
Thank you