subaward basics and subrecipient monitoring pilot · subrecipient basics and monitoring offered by:...
TRANSCRIPT
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
Subrecipient Monitoring
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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 Operates in a competitive environment
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
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
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
Subrecipient Monitoring
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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 Operates in a competitive environment
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Subrecipient Monitoring
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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 Operates in a competitive environment
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Subrecipient Monitoring
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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 Operates in a competitive environment
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Subrecipient Monitoring
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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 Operates in a competitive environment
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Definitions
Subrecipient Monitoring
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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 Operates in a competitive environment
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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 Operates in a competitive environment
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
SubrecipientVendor Determination
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 Operates in a competitive environment
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
SubrecipientVendor Determination
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 Operates in a competitive environment
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
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
SubrecipientVendor Determination
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
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
SubrecipientVendor Determination
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
SubrecipientVendor DeterminationCase Study
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
What should the proposal preparer do
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
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
17
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Office of Sponsored Projects (Pre-Award)(OSP)
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
Principal Investigator (PI)
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Department Business OfficeAdministrator (DBO)
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Preparing Negotiating and Executing Subawards
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
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Preparing Negotiating and Executing Subawards
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
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Subaward Setup Process
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Subaward Setup Process
27
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
28
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Department Business OfficeAdministrator
(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)
Principal Investigator
(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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Processing Subrecipient Invoices
DBOPI Review and Approval of Invoices (cont)
31
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
DBOPI Review and Approval of Invoices (cont)
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
Processing Subrecipient Invoices
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
Processing Subrecipient Invoices
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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)
Subrecipient Monitoring
35
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Subrecipient Monitoring
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
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Subrecipient Monitoring
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
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
38
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Closeout of Subawards
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Resources
Contact
bull OSP ContactAssignments Matrix
o httpyouryaleeduresearch-supportoffice-sponsored-projectssponsored-projects-contacts
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
o httpwwwgpogovfdsysgranuleCFR-2012-title2-vol1CFR-2012-title2-vol1-part220content-detailhtml
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
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
o httpyouryaleedupolicies-proceduresforms3205-fr01-vendor-setup-request
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
o httpyouryaleedupolicies-procedurespolicies3210-professional-services-and-consulting
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47
Click here to access the Quiz
You must take and pass the quiz in order to receive credit for the course
47