The Subaward Process Part One A Research Administrator s Guide

Transcription

1 The Subaward Process Part One A Research Administrator s Guide Anne Lesky, SPARCS Amy Herman, SPARCS With Assistance from Allison Nelson, C&G Brad Priser, C&G Learning Objectives After attending this session, you will: Know what proposal documentation to collect from each Subrecipient Understand the new process for Subrecipients in PINS View information from the Subrecipient Table in RADAR Submit a PMR subaward request under the new requirements Appreciate the steps involved in the subrecipient risk assessment process required prior to issuing a subaward 1

2 UG Summary of Subaward Changes Increased burden to support Subrecipient vs. Contractor decision ( ) F&A changes - Federally negotiated indirect cost rate (unless there is a program cap) or 10% MTDC de minimis ( & ) Increased burden on subrecipient monitoring ( ) and tracking of subrecipient s financial and programmatic reports ( ) Must document risk assessment for each subrecipient prior to issuance ( ) Requires process for screening and managing COI for PI and their subrecipients ( ) Federal Funding If source of funding is FEDERAL the subrecipient should have: A DUNS number (2 CFR 25) An active SAM registration Certain agencies implement through supplemental guidance NCSU uses SAM registration to confirm subrecipients representations, certifications, and assurances and to verify DUNS 2

3 The Subaward Process PROPOSAL PROCESSING 3

4 Subrecipient and Contractor Determinations UG clarifies that it is the PTE s responsibility to make subrecipient/contractor determinations on a case by case basis Characteristics and classification of subrecipients and contractors (previously called vendors ) remain the same as in A-133 Federal Agencies may require us to support our determinations If you have a Contractor Review Services/Contract Review Services.php 4

5 Subrecipient Proposal Package Signed Checklist determining Subrecipient or Contractor Letter of Intent signed by authorized signatory Statement of Work Itemized Budget Budget Justification Curriculum Vitae for each PI Copy of the federally negotiated F&A rate agreement, if applicable Proof of current compliance approvals Biosketches, pending support & other information required by Sponsor Indirect Cost Rate of Subrecipient Federally negotiated rate between the subrecipient and the federal government should be used; unless the program has a capped F&A rate If subrecipient does not have a federally negotiated rate, apply a de minimis rate of 10% of MTDC NC State University will not negotiate indirect cost rates with subrecipients 5

6 Fixed Amount Subawards & & Need prior written approval from awarding agency Include written request with justification for fixed amount subaward in proposal Limited to Simplified Acquisition Threshold ($150,000) Watch for exceptions in agency supplements! Can not be used in programs with mandatory cost share At close out, Subrecipient must certify in writing that the project is completed and/or the full effort occurred PINS 6

7 Adding Subrecipients in PINS A new question will be added to the second tab in PINS currently labeled Sponsors/Subs/Deadlines Upload Subrecipient s Proposal Documents 7

8 COI updates in PINS COI Question updated in Approvals/Routing: Do you have a significant financial interest in or other conflict of interest with the sponsor of this project OR any proposed subrecipient, subcontractor, vendor, or consultant? COI Representation and Certification language updated to include subrecipients, contractors, vendors, and consultants I have on file a current and up to date COI disclosure and have considered my relationship with this sponsor and all subrecipients, subcontractors, vendors, and consultants, if any, and find all such relationships either free of a conflict of interest or consistent with a previously disclosed, up to date, and active conflict of interest management plan. 8

9 Approval Certifications * portal/pins/help certifcation/ 9

10 PINS Approval Representations and Certifications Updated for Subrecipient certifications ** When you click APPROVE on the routing screen in PINS, you certify to the following regarding subrecipients: I certify that the subrecipient(s) was(were) selected based upon their technical expertise and ability to successfully perform the statement of work. (PI) I certify that the subrecipient s technical and cost proposals were reviewed and the activities proposed were found to be allowable and appropriate to meet the programmatic objectives of the project and that the costs proposed are allowable, reasonable, and necessary for the work to be done. (PI and CRO) RADAR 10

11 New Electronic Subrecipient Questionnaire Once the proposal is imported in RADAR, if needed, an electronic questionnaire will be automatically sent to the subrecipient RADAR: Subrecipient Table Search for subrecipients that NC State has previously worked with View risk assessment levels Request to add new subrecipients 11

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13 New Subrecipients not in PINS If a new subrecipient is not captured in PINS at the proposal stage: In Radar Subrecipient Table, request a new subrecipient A questionnaire will be sent and must be returned Risk assessment will need to be performed PMR 13

14 How to Avoid a PMR Return DO obtain prior approval from the Agency, if required DO ensure funds are in the prime Subcontract line DO upload required documents to PINS or PMR Subrecipient Proposal Package only upload docs in PMR if not in PINS Signed Checklist determining Subrecipient or Contractor Letter of Intent signed by authorized signatory Statement of Work Itemized Budget Budget Justification Curriculum Vitae for each PI Copy of the federally negotiated F&A rate agreement, if applicable Proof of current compliance approvals Biosketches, pending support & other information required by Sponsor 14

15 Rushes Rush Requests for Subawards Must include a Justification explaining the reasoning behind the rush Pursuant to the PMR manual, the RUSH field should only be used for the following criteria impending "agency imposed" deadline to submit request risk of loss of funding risk of loss of award risk of audit finding A subaward can not be issued until a Risk Assessment is performed on the subrecipient. RISK ASSESSMENT 15

16 The Risk Assessment Matrix NC State University has an obligation to perform a subrecipient risk assessment prior to issuing ALL subawards regardless of the type of funding Risk Assessment Check Points Subrecipient Questionnaire Indirect Cost Rate Audit Report NC Debarred Vendors List Compliance FDP FCOI Institutional Clearinghouse for NIH funding RCR for NSF, NIH, USDA NIFA Sam.gov Active registration FAPIIS Report Performance Integrity Visual Compliance Restricted party screening Key Personnel Entity 16

17 Determining Risk Risk will be assessed as either: Low (<=15): no anticipated measurable effect on achievement of project s goals and objectives High (<=24): Risk could compromise project goals and objectives or compliance with prime sponsor s terms and conditions (>=25): Requires management decision to go forward Subrecipient debarred or suspended, has a conflict of interest; Financial management and accounting systems are inadequate to account for award funds in accordance with federal requirements; NO DUNS registration; Subrecipient will not complete questionnaire High Risk Subrecipients High Risk Subrecipients Foreign entities For-profits with no annual audit Subrecipients with significant audit findings without a defined corrective action plan Monitoring requirements Increase frequency of financial and technical reporting On a case by case basis Request supporting detail with invoice Issue smaller increments of money Add stop work language for failure to comply Exercise right to perform audit, desk review, or perform site visit 17

18 SUBAWARD PROCESSING How to Find the Risk Level and Monitoring Responsibilities 18

19 Next Steps Obtain PI feedback regarding subrecipient performance quarterly, prior to issuing modifications, and/or at close out to use as additional risk assessment factor and as part of subrecipient monitoring to document that we are tracking reports Subaward Training Part Two, Subrecipient Monitoring Who do I contact for help? Anne Lesky, Compliance Accountant & QA Amy Herman, Assistant Director for Subawards 19