The New OSP Request for Subaward & Subrecipient Monitoring Course

1. The New OSP Request for Subaward & Subrecipient Monitoring Course Dana Simpson: Contracting Officer, Sub-agreements Team Rob Roy: Director of Board of Regents Sponsored Programs Garrett Steed: Training Program Manager

2. Overview • Definitions and policies • Georgia Tech’s policies • Subrecipient • Request for Subaward • Vendor • Roles • Responsibilities • Risk • Authorization

3. Georgia Tech’s Responsibility • Georgia Tech is responsible for ensuring that all subrecipients of its sponsored research awards are in compliance with applicable requirements.

4. Georgia Tech’s Guidelines

5. Who is a Subrecipient • OMB A-133: A Subrecipient is a legal entity to which a sub award is made and which is accountable to the recipient for the use of funds provided. • Financial assistance, or procurement , or contract made by a recipient to an eligible Subrecipient

6. Subrecipients vs. Vendors • OMB A-133 B.210 Federal award. Characteristics indicative of a Federal award received by a subrecipient are when the organization: (2) Has its performance measured against whether the objectives of the Federal program are met; Payment for goods and services. Characteristics indicative of a payment for goods and services received by a vendor are when the organization: • Provides the goods and services within normal business operations; • Provides similar goods or services to many different purchasers; Design and Develop (Sub) vs. Configure (Vendor) • http://www.whitehouse.gov/omb/circulars/a133/a133.html#b

7. Subrecipients vs. Vendors • Vendors are Not Subrecipients: and therefore do not include the purchase of goods and services • Entities with in the USG can be an exception to this rule Design and Develop (Sub) vs. Configure (Vendor)

8. Identifying eligible Subrecipient entities • That are willing and able to comply with the requirements of the award • Have accounting systems that are adequate to administer the award • Have not been suspended or debarred from receiving federal funds

9. Preparing a Statement of Work: SOW • The Statement of Work is a document that: • lists and describes all essential and technical requirements for the effort to be performed • including standards to be used to determine whether the requirements have been met. • Set your expectation and reporting requirements early, put them in the sub-award

10. SOW should include: • Objective or Purpose • Period of Performance • Milestones • A list of detailed work requirements • Workload requirements • Personnel requirements • Resources (if any) to be furnished to the subcontractor

11. Process Flow Pre-award Post Award Identify need for Subaward Accept & IncorporateInto Proposal Find New Subaward No PD/PI Enter Subaward Request Into WebWise System Communicate with PI & support staff to address issues Addressed? Review Proposal Formal Request Yes No No Yes Approve Review and Affirm Compliance OSP Submit FormalRequest Submit ProposalApp. Subaward Executed Yes Sub Review Terms Accept or Negotiate Terms Review Request Prepare & SendProposal

12. Beginning a Sub Agreement Process • To initiate: you willneed to log into WebWise, using your GT account ID and Kerberos password. • Under the OSP Contract Information System tab you will find a section for Subagreement Management.

13. Step 1 • To complete an on-line "Request for a Sub-Agreement" you will need to have • a detailed budget • statement of work (including deliverables & reports) • a short narrative as to why you selected the subcontractor • as well as a cost/price analysis

14. Step 2 • Enter your budget

15. Step 3 • Upload: a short narrative as to why you selected the subcontractor • as well as a cost/price analysis

16. Step 4 • Upon final submission in the on-line system an email will be sent to the Subagreements Team • Notifications on progress will be sent via the ICOL system.

17. Old Process Flow Generates Invoice Process Complete Payment Received Back to Sub for more detail Sub “Firsthand Knowledge” PD/PI No PI reviews Approve receives invoice Yes Dept.Admin Enter into PeopleSoft A/P Check Issued

18. New Process Flow Generates Invoice Process Complete Payment Received Back to Sub for more detail Sub “Firsthand Knowledge” PD/PI No PI reviews Approve receives invoice Yes Dept.Admin Enter into PeopleSoft Add Meta Data on ImageNow Update on ImageNow A/P Check Issued Receive Invoice Code Invoice & post on ImageNow OSP Coding and scanning includes adding meta tags such as; PI, Fund #, and Amount

19. A framework for compliance and expectation • Reports = Document program progress • Invoices = Request supporting material • Budgets = Evaluate progress • Tracking = Oversight (IRB reviews) • Supervise = Understand where and why • Authorization = Collect documentation

20. Reports and Invoices • Reviewing subrecipient reports and billings, and following-up on areas of concern • Does the billing/invoices amount accurately represent the amount of scientific data or progress by the sub? • Is there sufficient supporting documentation to determine if the expense on the invoice are allowable? (Think 3 years down the road)

21. Budget • Monitoring subrecipient budgets • Is the sub spending the money too quickly? Will they run out before the work is complete? • Is the sub having trouble getting started on the project?

22. Tracking • Tracking to ensure timely submission of required reports • WebWise:

23. Authorization documentations: • Know ahead of time what type of communication and how to authorization occurs • Signature Authority: who has it? • PI approval documentation • Document…

24. Short Break

25. Roles, Responsibilities & Risk • Office of Sponsored Programs (OSP):ensuring that the Institute’s subrecipient monitoring procedures are compliant with regulations.  • Unit Financial Officers (Departmental Administrators):assist PI’s in carrying out their responsibilities.  • Principal Investigators (PI): is ultimately responsible Regulations Documentation Verification

26. Roles, Responsibilities & Risk • Office of Sponsored Programs (OSP):  ensuring that the Institute’s subrecipient monitoring procedures are compliant with federal and other applicable regulations this include: • Compliance requirements • Flow-down provision: Prime to sub • Debarred or suspended check • Audit certification letters from subrecipients

27. Roles, Responsibilities & Risk • Unit Financial Officers (Departmental Administrators): assist PI’s in carrying out their subrecipient monitoring responsibilities includes: • Reviewing • Invoice Approve & to A/P • Excessive charges request clarification • Maintain Invoices • Maintain documentation of monitoring efforts • Verify or confirm cost share (if required) has been met by Sub

28. Roles, Responsibilities & Risk • Principal Investigators (PI): management of federally funded projects includes: • Monitor • Review • Verifying • Approving • Allowable, Allocable, Reasonable, & Period of Performance • Keep records of notes of phone conversations and email correspondence

29. Roles, Responsibilities & Risk • 4 Subrecipients Classes • Not-for-Profit: Large awards >$500,000 • Not-for-Profit: Mid-sized awards $100,000 – $500,000 • For-Profit Entities • Non US-based entities

30. Risk Factors • Size of the sub-award ($50,000 vs. $5,000,000) • Percentage of pass-through • Complexity of sub-award • Sub-recipient’s experience • Administering • Deliverables • Prior monitoring and audit results • Single year vs. multiyear sub-award • Type of entity • OMB-A-133 or not • Non-profit/Profit • Domestic/Foreign

31. Know your sub-awardee • Sub-recipient monitoring begins at proposal development • An understanding of the capabilities of your sub-awardee can, and should drive your budget development and monitoring plan • Assess the awardee • Assess the level of expertise (Institution/College/Department) • Review what can be monitored • Tailor the agreement

32. Know your sub-awardee • Know your sub-awardee • Review the latest A133 audit • Assess the SOP for Documentation • IRB (document IRB oversight and that it remains current ) • IACUC • Effort reporting – overload payments • Committed Cost Share • F&A (not everyone uses MTDC) • Assess your risk • Set your expectations and reporting requirements • Delineate your deliverables – put them in the sub-award contract (request supporting documentation for each invoice)

33. Financial Reports • Recommend quarterly financial reports with business official signature • Makes sure everybody is watching • Triggers and focuses review in manageable bites • Reconciles invoices / payments / receipt of payment (facilitates annual report) • Include progress on cost share • Remember to document a relationship between programmatic progress and financial expenditures

34. Keeping Risk In Mind… • What is your purpose of sub-recipient monitoring? • Compliance • Need for technical assistance • Follow-up • What is the associated risk of noncompliance • Experience of your sub-recipient

35. Risk Exercise

36. Overview & Closing Initiation Planning & Submission Closing/Transition Execution Monitor • SOW • Requirements • Milestones • Deploy Iterative: test & evaluation All RISK Assessment & Mitigation PD/PI Proposal Development & SOW Eligible Subrecipient or vendors Reviewing Invoice Approve Deliverables Final Report & Deliverables Dept. Proposal Routing Sheet Set up infrastructure for project and monitoring Maintain Scanned Invoices & documentation – sending to A/P Archivedocumentation for Audit OSP Verify Institutional Requirements Submit Proposal Debarred & Suspension Check Maintain Scanned InvoicesCompliance RequirementsAudit Letters CloseoutProcedures

37. Thank you