Subcontracts Procedures and Federal Regulations

1. SubcontractsProcedures and Federal Regulations Susan Tompkins George Walueff

2. TOPICS • Purchase Orders • Consulting Agreements • Subcontracts • Budget impact • Initiating Subcontracts • Invoices

3. Subcontracts • Performs substantive programmatic work under a grant or contract • Bears responsibility for programmatic decision making and measurable performance requirements • Subcontractor must adhere to compliance requirements of the primary award

4. Subcontracts Continued…… • Requires prior written permission of the sponsor. If in the proposal, award provides permission. If need arises for subcontract after award is made, required prior approval from the sponsor. • NOT AN EMPLOYEE OF UD

5. Subcontracts • If, using the above criteria, you determine the service required is a subcontract then: • Complete the Provider Category Determination Worksheet • Reviewed by OVPR and Procurement Services

6. Purchase Orders • The procurement of goods or services from an organization which provides the goods and services to many different purchasers as part of its normal business operations within a competitive environment • With federal funds, not subject to same requirements as subcontractor • NOT AN EMPLOYEE OF UD

7. Consultants • NOT AN EMPLOYEE OF UD • Proven professional or technical competence • You do not control manner of performance or result of service • Work for hire • UD retains rights to end product

8. Budget Implications • Subcontracts – first $25,000 charged facilities and administration costs • Purchase Orders and Consultants – facilities and administration costs charged on all dollars • This information should not be used to determine provider category

9. Subcontract Initiation by Dept. If proposal is funded: • Provide to OVPR • Provider Category Determination Worksheet (formerly OMB questionnaire) • Contact information • Statement of Work • Budget • Budget justification • Prepare Purchase Requisition • With the information above attached

10. Subcontract Initiation by OVPR • Upon receipt of paperwork, OVPR prepares subcontract letter with attachments and forwards to Subrecipient • Initiates negotiations with Subrecipient • Work should not begin until award is issued

11. Subcontract Initiation by Procurement • Procurement Services • Reviews Provider Category Determination Worksheet • Obtains additional approvals as required • <$50,000 Account Administrator, OVPR • $50,000 - $100,000 also Dean • >$100,000 - $250,000 also Provost • >$250,000 also President • Obtains W-9 for tax id if not provided • Issues purchase order for payment purposes • Subrecipient does not get copy

12. Invoices • Received by OVPR • Forwarded to Principal Investigator for approval • Invoices should include: • Summary of expenses by category • Dollar amount • Date • Subgrant # • Each invoice must contain the required certification (see Attachment 1): • PI approves invoice and returns to OVPR • OVPR sends to Procurement Services for payment

13. Subcontract Close-out • Subrecipient required to submit • Final Technical Report (Interim reports may be required by the Principal Investigator, this will be specified in the Subcontract) • Final Invoice (including cumulative costs and Cost Share) • Equipment Report • Patent/Invention Report • Subrecipient Release Forms

14. USEFUL INFORMATION: • Office of the Vice Provost Office Website, FAQs http://www.ovpr.udel.edu/OVPR/do/index?pageId=43

15. Questions?