Streamlining (sub)Award Management

Streamlining (sub)Award Management Office of Sponsored Programs May 21, 2011 ospoff@syr.edu X2807

Today’s goals… Get us all on the same page… • Help us learn about you • BBI’s organizational structure • Folks’ roles/responsibilities • How you operate at various stages of the lifecycle • Review Sponsored Project lifecycle & guiding principles • Strategize on how to more efficiently work together to • Facilitate achieving the award’s goals & objectives while adhering to sponsor’s requirements & SU policies / practices

Guiding principles • Spending Federal Dollars • Comes with strings attached • Want to avoid knots or the noose • Why?? • Fed’s expectations: ?? • At proposal submission – SU agrees to follow award’s terms and conditions including following SU policies/procedures, reporting requirements & the cost principles, which require that costs are: • Allowable – under terms of award and SU or entity policy • Allocable – can reasonably determine benefit received by award and cost proportional to benefit • Reasonable – prudent person test (necessary) • Consistently treated – either direct cost or indirect cost

About BBI • BBI’s organizational structure • Folks roles/responsibilities • How you operate at various stages of the lifecycle including communications & information management

The Sponsored Project LifecycleTransparency & Accountability to Avoid Fraud, Waste & Abuse

Find Funding Opportunities • How & Who? • Go / no go process • Who notifies OSP (MMcB) about plans & when ? • COS • IRIS • Grants.gov / fbo.gov • Distribute to BBI leadership BBI’s activities OSP

It’s a go – you’re going to apply • Who’s responsible for what? • Needs • FOA information ASAP • URL • PI & team • Partners (non-SU) • Ltr of Com’tnt AOR • SOW • Budget required format • Time to review & authorize • 7 b-days: budget • 3 b-days: complete app • Service guidelines BBI OSP

You’re Applying…. • Internal Review • What is goal of project? • Who has expertise? • BBI? • Collaborators?? • What is each group doing? • Cost? Parts and whole • Info Management • Version control • Naming conventions • Reviews • Application adherence • IRR congruence • Confirmation of 3rd party approvals • FAR exceptions • Lots of other stuff… • Submits BBI OSP

Subrecipient / Vendor / Consultant Decision to be made at proposal stage. • Not all treated the same in terms of F&A • Regardless of Type of 3rd party relationship – • In advance, have a SOW or at a minimum a clear understanding of what they will do for you • Characteristics of subrecipients, Vendors (purchased services) or consultants • Lots of detailed information • Subrecipient • Responsible for work and award performance • Subject to certifications/assurances (Human Subjects) • If at SU – would be PI or other key personnel

Subrecipient / Vendor / Consultant • Vendor • Services provided are core to their mission • Provide same services for many customers • Price published or same rate for similar customers • May be non-profit organization • Caveat – IHE’s procedures may impact agreement type • Consultant • Individual who provides advice or discrete service modest scale • A type of vendor in terms of award T&C (e.g., not subject to human subjects assurances but may be subject to confidentiality provisions.) • Is “work for hire” • Use ‘worksheet for non-SU employees”

Reminder - Application… • Made up of many parts… • Much of our focus is on: • Project plan – narrative, description etc • Including Statement of Work (SOW) • Budget • Budget justification

SOW vs Budget - two sides same coin - SOW SOW Budget Budget is financial expression of statement of work (SOW). Work drives costs; each collaborator should define & “own” SOW

Project Work Plan comprises…

Award Negotiation & Set Up • OSP responsibilities / tasks • BBI’s responsibilities / tasks • Subrecipient process  under award management

Negotiate Award - OSP • Grants / Contracts– • Standard Terms & Conditions or Troublesome clauses (reviewed and identified at proposal submission) • Where FAR exceptions accepted? • Was there a modification to submitted budget or work plan? • Adjust key personnel effort • Modify scope of work • Allowable costs?

Award Set up - OSP • Compliance check • Human subjects congruence • COI all folks • Debarment/suspension • IRR • etc

Common omissions  delays… • No Internal Routing and Review form • No current COI for key personnel • Human subjects protocols pending • Allocate $$ (easier if clear up front) • Human Subjects • Not Human Subjects • Allocation of award to multiple SU units not clear

After negotiation & compliance reviews… Award Set up - OSP • OSP  OSA for Chartstring creation (new award) • OSP  BBI PI, budget manager & project manager • Award package: chartstring, T&C etc. • New – OSP will confirm with BBI that any 3rd party partners are the same as in proposal • OSP will request institutional profile & conduct risk assessment

What about forward funding? • When GRANT agreement isn’t in hand – request as soon as known and practical • Contracts: only when we know start date and it’s not effective dated; high risk • Same compliance reviews as for awards • Not allowed • Subrecipient costs • Human subjects costs without congruence complete

The Sponsored Project Lifecycle Transparency & Accountability to Avoid Fraud, Waste & Abuse

Manage the award - discussion • Responsibilities • PI • Day-to-day • Financial • Subrecipient • Consultants • Information management • Negotiate amendments • Obtain sponsor prior approvals • Facilitate (sub)award administration • Facilitate compliance with SU / sponsor’s policies, T&C BBI OSP

Award Mngt: Worth repeating… • Review all expected obligations upon receipt of award materials • ALL BBI personnel effort: review / revise upon receipt of every new award and anticipated award. • 3rd party collaborations – plan ahead • Standing orders – plan ahead • Avoid confirming invoice attached • Not named folks debarment / suspension (epls.gov) • Review award materials especially terms and conditions to know what you can & can’t do. • DoL & cooperative agreements much less flexibility • You can’t move named personal around at will. • CONSIDER – name only essential folks

Subaward process Transparency & Accountability to Avoid Fraud, Waste & Abuse

Subrecipient Management - OSP • From risk assessment, develop subaward • Cost reimbursable vs fixed price WHY • Reporting requirements • Financial supporting docs etc • Execute subagreement • Create PO in ePro • Set up in SADb • Send subagreement to BBI • Monitor ‘process’

Manage the (Sub)award – BBIdiscussion • Managing your Award • Award Management Aid

Common challenges… and the consequences • Collaborators • Letters of commitment from authorized rep. • Partner may reject award • Certs & Assurances not obtained from subaward  delays • Budget / budget justification • Financial risk • Statement of work missing or • Ambiguous standards of performance • Not unique to project • Errors in management • “Braiding & Blending”  allocobility concerns

Deep Dive: Request to • Issue New subaward • Modify Existing subaward • Proposed- Subaward materials Transmittal

Subaward Db - screenshot

Other matters Questions frequently asked of OSP • Why am I not being paid??? • There is no agreement in place • No agreement – no obligation by SU • No invoice has been received • No invoice – no way to pay • Invoice review guidance

And a year goes by…. • Continuation…

Non-competing continuationsProcess varies by sponsor • Annual Progress report • Complete ‘continuing application’ • HINT: Work with sub’s same time to obtain updated SOWs and budgets for next budget period (~90d out) • Carry over? • Signs as authorized official or AOR, as required. • Reviews /approves budgets • Requests carry over, as applicable BBI OSP

Potential speed bumps • OSP not informed of continuation process • Subaward continuation challenges • Not done in a timely manner • Ambiguous statement of work • SOW similar to other awards • Budget poorly justified with little linkage to SOW • Inadequate budget justification • Baton gets dropped along the way – Communications / info management challenges • Agreement execution • Invoice management

Close-out • Formal process to ensure that all University obligations to sponsor have been met. • Programmatic • All required reports • Invention reports • Financial • Final Financial report • Review all documentation • Property Reports • Subaward – as above

When bad things happen to good people • Accepting federal $$ comes with MANY obligations, i.e there are strings attached. • Current administration – • Transparency and accountability to avoid Fraud, Waste, and Abuse • Braiding and blending is not consistent with the allocobility cost principle • You will be audited. • Following regulations, policies & SU procedures; timely actions; and complete documentation are best protections against questioned costs, embarrassment, loss of reputation etc.

Last audit • Late awards to SU • Impacts subawards • Effort Reporting • Cost transfers – too many, and not timely • Debarment & suspension • Must be done prior to hiring • Sub’s – we ask for certification, but they are responsible for conducting epls check

Future audits (IG work plans / A-133) • Effort – personnel compensation and supplemental pay (Extra Service) • Subawardee effort procedures • Travel – especially foreign travel • Recharge Centers • Subrecipient monitoring • Administrative costs • Eligible activities

Summary • Accepting federal $$ brings with it the obligation to be responsible steward of those $$ • Efficient and effective practices facilitate stewardship • Strategize / document what can we each do to support this goal…

Streamlining (sub)Award Management