Outgoing Subawards

1. Outgoing Subawards DSP: Wendy Beaver GAO: Jodi Kennedy June 12, 2015 Kathie Gonzales Angie Klein Britt Murdock Edie Pierce-Thomas Angi Roemerman

2. References • DSP Subaward Website • http://dsp.research.uiowa.edu/subawards-university-iowa • Process Flow Chart • Roles & Responsibilities • Subaward Forms • UI Outgoing UG Subaward Quick Guide • DSP Staff Directoryhttp://dsp.research.uiowa.edu/dsp-staff-directory

3. References: UG Definitions • 2 CFR 200.74 Pass-through entity means a non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program. 2 CFR 200.74 • 2 CFR 200.92 Subaward means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass-through entity. • 2 CFR 200.93 Subrecipientmeans a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program.

4. References: UG Definitions • 2 CFR 200.23Contractor means an entity that receives a contract as defined in 2 CFR 200.22. • 2 CFR 200.22Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award (e.g., a purchase order at the UI). The term does not include a legal instrument when the substance of the transaction meets the definition of a Federal award or subaward.

5. Proposal StageSubrecipient or Contractor • Pass-through entity is responsible for deciding whether an arrangement is a subaward, contract, or consulting arrangement. • Subaward: Carrying out intellectually significant portion of the federal award; Key personnel may be considered authors on publications; work requires IRB or IACUC approval. • Processed through DSP • Contract: Obtaining goods and services; procurement relationship; provides a routine service in a competitive environment; provides similar goods or services to many different purchasers. • Purchase order issued by UI Purchasing • Consulting: Advisory services • Professional Services Agreement issued by UI Purchasing

6. Subrecipient or Contractor • Additional resources: • DSP Subaward website http://dsp.research.uiowa.edu/subawards-university-iowa • FDP Checklist to Determine Subrecipient or Contractor Classification • Determining the appropriate relationship at proposal stage is critical to ensure appropriate accounting for costs and compliance requirements.  Misclassification may result in delays in proposal submission, subaward processing, inaccurate calculation of costs (e.g., failure to include or exclude F&A costs), and require additional time to request approval for project changes.

7. Subrecipient or Contractor • PI has initial responsibility to determine collaborator’s status • PI/Department are encouraged to consult with DSP in advance of proposal submission • Collaborating with individuals or sole proprietors: Professional Services Agreement (PSA) through UI Purchasing • Collaborating with another UI department (this is not a subaward handled through DSP)

8. Proposal Submission • Include Subrecipient’s budget and other required information in the UI proposal (i.e., budget justification, Letter of Intent, etc.) • Consult with potential Subrecipient sites prior to proposal submission to obtain accurate budget information for proposal. • Consider sponsor requirements: • Forms • Budget categories • F&A • Conflict of Interest in Research • Fixed Price Subawards under the Uniform Guidance • Other requirements in funding announcement Fixed Price subawards must be explicitly and clearly requested in the Proposal with proper justification. We don’t want costs disallowed by the Sponsor-be prudent & detailed in your justification & budget request.

9. F&A on Subawards • Subrecipient’s federally negotiated F&A rate must be used on subawards unless a lower rate for the project is published by the sponsor (e.g., NIH caps F&A for foreign subrecipients at 8%). • For subrecipients without a federally negotiated F&A rate, 10% MTDC F&A rate must be used on federal awards. • NSF-if a subrecipient does not have a U.S. federally negotiated F&A rate, the 10% de minimus rate must be used (no less as that is considered voluntary committed cost sharing which is not allowed). This new rule applies to foreign subrecipient sites as well.

10. Fixed Price Subaward Requirements • 2 CFR 200.332, 200.201 • Prior written approval from Federal awarding agency (Note: if Fixed Price Subaward was in original proposal NIH’s award notice constitutes approval, all other agencies must have specific approval) • Cannot exceed $150,000 cumulatively (simplified acquisition threshold) • Fixed Price subaward amounts do not fall under the re-budgeting authority. Sponsor approval is required to move funding to or from this category. • Fixed price amount is negotiated using cost principles or other pricing information as a guide • Fixed price subawards are not allowed if there is mandatory cost sharing or match • At the end of the subaward, subrecipient must certify the project or activity was completed or the level of effort was expended

11. Project is Funded: It’s time to Issue the Subaward • If Subrecipient is other than U.S. university, send the Audit Certification and Financial Status Questionnaire to Subrecipient • PI negotiates scope of work and budget with Subrecipient • Statement of work conforms to requirements of Prime Award

12. Issuing a New Subaward • If Subrecipient is a new vendor to the UI, send Vendor Application Form to Subrecipient • If Vendor is in database, but new address is needed, e-mail Purchasing Vendor File Team (VFT) purchasing-vendor@uiowa.edu with Vendor name, new address, phone, and contact person.

13. Advance Payments • If there will be an Advance Payment to the Subawardee, review the Advance Payment instructions, requirements and UI established payment schedule. • Advance Payments • PI Subawardee Monitoring Assurance • Subawardee Request for Advance of Funds • Requires DSP and GAO approval • Once PO is created PI/department must complete “Advance Payment Request Form” to process first payment • Initial payment is 20% of annual award + equipment; Quarterly payments thereafter

14. Complete the Preq • Use Category Code 99990000 – specific for Subawards • List subaward period of performance dates • List direct and F&A cost figures for the subaward budget period • Attach the statement of work • Attach the detailed budget, including supporting documentation for fringe benefits if not federally negotiated • Attach the Subaward Reporting Requirements form (required for subawards and amendments under federal grants).  This form is recommended for other subawards. PI should determine reporting periods. • Attach Audit Certification and Financial Status Questionnaire (required for Subawardees other than U.S. accredited institutions of higher education) • Attach other documentation as required by prime award • If replacing an existing PO, list the previous PO number • If requesting advance payment, attach advance payment forms • Route the Preq through Workflow

15. Preq

16. Types of Subawards • DSP drafts the subaward • UI prefers to issue cost-reimbursement subawards • Fixed price subawards under the UG have specific requirements and limits • Generally UI follows the prime award type of agreement

17. Subaward Invoices & Payments • Subrecipient should submit invoices directly to GAO for payment • B5 Jessup Hall, Iowa City, Ia • uigao-subawardeeinvoices@uiowa.edu • Cost-reimbursement subawards – subrecipient invoices the UI no more often than monthly • Subawards that include an Advance Payment schedule – subrecipient invoices the UI quarterly; monthly/quarterly financial reports must also be submitted

18. Subaward Invoices & Payments • GAO reviews invoices and sends to Accounts Payable for payment • Invoice adequately meets UI invoice requirements • Invoice includes Certification statement and is signed • Invoice period falls within the Subcontract budget period • Reviews invoices for consistency with subaward budget • PI/Department receives notification from Accounts Payable that a Subaward invoice requires “Receipt” • Review invoices for consistency with subaward budget • Assess that invoice is reasonable in light of subrecipient progress • Assure compliance with the terms of the prime award • “Receipts” voucher and approves payment through the e-Pro system • PI/Department contacts AP and GAO immediately with questions or if payment of an invoice should be placed on hold

19. SubrecipientMonitoring • PI, Department and GAO all have monitoring obligations • PI receives progress and invention reports • PI maintains documentation of review (email, annotation with “reviewed” and date) • PI maintains subrecipient reports and other documents for the required document retention period (for federal awards generally three years from the project end date) • PI monitors financial and programmatic progress of subrecipient • PI notifies DSP and GAO immediately with concerns involving subrecipient performance

20. Subrecipient Monitoring • Annually GAO requests and reviews subrecipient audits and/or financial reports • GAO may determine additional documentation or reporting requirements are needed • GAO works with DSP if changes are needed

21. Subaward Closeout • Grant Accounting sends a copy of the final invoice to the PI and Department for approval before sending to Accounts Payable • PI/Department confirms completion of work • PI/Department reviews final expenses • PI/Department assures all required progress and invention reports have been or will be received • Fixed Price subawards only - GAO requests Certificate of Completion from subrecipient • If necessary, Department and GAO work with AP to close Subaward PO

22. Subaward Amendments • http://dsp.research.uiowa.edu/revising-existing-subaward • BR (Budget Reference) for the prime award is indicated on the AAAN • If the BR has not changed from the previous subaward, submit a Subaward Amendment Request Form • If the BR has changed from the previous subaward, submit a new Preq

23. Carryover under Outgoing Subaward Amendments • If the BR does not change • The UI’s default is to add new funding to the previously authorized subaward amount (i.e., the UI automatically approves carryover of unexpended funds). • If the PI/department does not want to authorize carryover, contact DSP before submitting the subaward amendment request form • If the BR changes • The UI’s default is not to authorize carryover • If carryover is requested, contact DSP • Sponsor approval • Confirmation of the amount of unexpended funds • PI’s approval

24. Uniform Guidance (UG) Overview Effective Dec. 26, 2014, 2 CFR 200 (replaces A-21, A-110, and A-133) Does the UG apply to my federal grant? • NIH and NSF: UG applies to award notices dated 12/26/2014 or later that provide funding • ONR: If the award notice provides incremental funding for an existing award and the initial award was issued prior to 12/26/2014, the UG does not apply. If the award notice provides funding and does not meet the above existing award criteria, the UG applies. • Other federal agencies: If an award notice was issued on or after 12/26/2014, the UG applies

25. UG Requirements • No commingling of federal and non-federal funds (i.e., only 1 MFK per Preq) under awards subject to the UG • Additional subrecipient risk assessment monitoring • UI financial questionnaires have been revised to reflect UG rather than A-133 requirements: • New audit threshold is $750,000 in federal financial assistance • Invoices must include new certification as required in 2 C.F.R. 200.415(a) • Required documentation of UI PI’s receipt and review of Subrecipient progress and invention reports • Certificate of Completion required for Fixed Price Subawards

26. Revised process • GAO is working with AP to add assurances to the voucher Receipt notification email • May also add assurances to the Receipt process within e-Pro • Starting July 1, all final subrecipient invoices will be sent to the PI and Department Administrator for approval • PI will always be included on the email • Email will clearly state that by approving final payment, the PI is assuring completion of work and expenses and their retention of required reports • GAO will require Certificate of Completion for Fixed Price Subawards

27. Changes to UG Subaward Format • FDP Subaward Templates http://sites.nationalacademies.org/PGA/fdp/PGA_063626 • DUNS number is referred to as “Unique entity identifier” • Central Contractor Registration (CCR) and Excluded Parties List System (EPLS) no longer exist as standalone systems; functionality is included in System for Award Management (SAM) • Attachment 4, Reporting Requirements • Attachment 6, UI specific terms – See screen shots for images of the new face page and where the G/P number, Preq & PO numbers appear on Attachment 6.

28. Changes to UG Subaward Format

29. Changes to UG Subaward Format

30. Changes to UG Subaward Amendment Format

31. Finding Subaward Documents and Status Information • DSP Research Tracker • Search by: • ReqID Number • PO Number • Subrecipient Name • UI PI Name • UI Grant/Program Number • UI Sequence Number • Click on “project”, then Expand Out Going Subawards (click on “+”) to see status information

32. Contact Us • Division of Sponsored Programs (DSP) • 2 Gilmore Hall • Phone: 335-2123 • Email: dsp-contracts@uiowa.edu • Grant Accounting Office (GAO) • B5 Jessup Hall • Phone: 335-3801