COLUMBIA UNIVERSITY POLICY ON SPONSORED PROJECT SUBAWARDS

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1 COLUMBIA UNIVERSITY POLICY ON SPONSORED PROJECT SUBAWARDS I. Introduction Published: July 1, 2015 As the recipient of a primary award for a Sponsored Project, Columbia University (Columbia or the University) may award financial assistance to a Subrecipient to facilitate performance of and payment for specific work to be conducted by such Subrecipient in connection with the Sponsored Project. As a condition to its acceptance of funding from a sponsor, the University is obligated in its role as recipient of the primary award to undertake certain stewardship activities and to ensure compliance by the Subrecipient with federal, state and local laws and regulations and with the restrictions placed upon the primary award by the sponsor. When the University assigns responsibility for conducting a portion of the work under the primary award to a Subrecipient, the University remains responsible to the sponsor for managing funds and meeting performance goals. This responsibility involves (a) pre-award assessment of the proposed Subaward and Subrecipient, (b) post-award monitoring of the programmatic and financial activities of the Subrecipient under the Subaward and (c) at close-out, determination that applicable administrative tasks and project work have been completed by the Subrecipient. This Policy applies to Subawards issued in connection with Sponsored Projects undertaken by investigators at the University regardless of the primary source of funding. This Policy reflects the provisions of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (CFR, Title 2) (the Uniform Guidance), and in particular Sections thereof, that was issued by the federal Office of Management and Budget (OMB) on December 26, 2013 and became effective for federal agencies as of such date and for non-federal entities, such as the University, as of December 26, The Uniform Guidance supersedes, among other regulations, OMB Circulars A-110 and A-133. Capitalized terms used in this Policy without definition are defined in Section III(A). II. Policy History The effective date of this Policy is July 1, This Policy replaces the Policy on Sponsored Project Subawards, effective April 1, 2008 and revised September 24, 2008 and January 26, III. Policy Text A. Important Definitions 1

2 As used in this Policy, the following terms have the meanings set forth below: Fixed Amount Subaward: a type of Subaward under which the Subrecipient provides a specific level of support without regard to the actual costs incurred under the Subaward. Risk Review Committee: a Committee whose membership includes representatives from SPA, RPIC and the Office of the Controller. RPIC: the Research Policy and Indirect Cost Division of the Office of the Controller. SPA: Sponsored Projects Administration. Sponsored Project: as defined in Chapter I, Section D(1) (Introduction: Sponsored Projects vs. Gifts) of the Columbia University Sponsored Projects Handbook. Subaward: a written agreement made between the University and a Subrecipient to perform a portion of the work under a Sponsored Project. A Subaward must include a clearly defined, intellectually significant Statement of Work (SOW) to be performed by the Subrecipient. The Subrecipient s SOW is performed by its personnel, using its own facilities and resources. The Subrecipient takes full responsibility for adhering to the terms and conditions of the Subaward, including those that flow down from the University s sponsor, and assumes creative and intellectual responsibility and leadership as well as financial management for performing and fulfilling the Subrecipient s SOW within the Subrecipient s approved budget. Subrecipient: a non-columbia entity that expends funds received from the University to carry out a portion of the University s programmatic effort under a Sponsored Project. A Subrecipient may not be an entity that is also a direct beneficiary of such Sponsored Project. The Subrecipient may be another educational institution, a foundation, a for-profit corporation, a non-profit corporation or other organization, and may be a domestic or foreign entity. B. Certain University Subaward Policies It is University policy that Subawards are funded for a maximum of one year, renewable for additional periods as appropriate. Modifications to existing Subawards may need to be negotiated with the Subrecipient and are dependent on the continuation of the primary award. In accordance with federal regulations, it is University policy that the University awardee perform a substantive role in carrying out the activities of a project and not merely serve as a conduit for an award to another party. It is expected that the aggregate amount payable under Subawards in respect of any award made to the University should not exceed 50% of such award without the prior approval of SPA and, in certain circumstances, the Risk Review Committee. See Section D(2) below. The University generally issues Subawards on a cost-reimbursement basis. With the prior written approval of the sponsor, if required, the University may issue Fixed Amount Subawards if the project scope is specific and if adequate cost, historical or unit pricing data is available to establish a Fixed Amount Subaward with the assurance that the University 2

3 will realize no increment above actual costs. The fixed costs of a Fixed Amount Subaward under a federal prime award may not exceed $150,000. C. Distinguishing Between a Subaward and a Contract 1. Importance of and Responsibility for Proper Classification The proper classification of a transaction as a Subaward or a procurement transaction (called a Contract in the Uniform Guidance) at the time it is proposed is critical to ensure proper accounting for costs and compliance requirements. Misclassification may result in delays in Subaward processing or inaccurate calculation of costs. The Principal Investigator (PI) of the Sponsored Project is responsible for determining the classification at the time that funding is first requested from the sponsor. 2. Distinguishing Characteristics of Subawards and Contracts The University follows the Uniform Guidance in determining whether a transaction is a Subaward or a Contract and the PI must make a case-by-case determination whether each agreement that is made for the disbursement of funds casts the entity receiving the funds in the role of a Subrecipient or a contractor. Generally speaking, a Subaward classification is appropriate when: The University (within the sponsor s guidelines) determines who is eligible to receive the Subaward. The entity has its performance measured in relation to whether the objectives of the Sponsored Project are met. The entity is responsible for programmatic decision-making. The entity is responsible for adherence to applicable Sponsored Project requirements. The entity uses funds to carry out the Sponsored Project rather than providing goods or services. Generally speaking, a Contract classification is appropriate when: The entity provides goods and services within normal business operations; The entity provides similar goods and services to many different purchasers; The entity normally operates in a competitive environment; The entity provides goods and services that are ancillary to the operation of the Sponsored Project; and The entity is not subject to the compliance requirements of the sponsor as a result of the Contract. The PI must use judgment in making the determination and in doing so, the substance of the relationship is more important than the form of the agreement. All of the characteristics listed above may not be present in all cases. The determination will be documented on a 3

4 Checklist To Determine Subrecipient or Contractor Involvement (the Subrecipient/Contractor Classification Form) (attached hereto as Appendix A). The Subrecipient/Contractor Classification Form must be submitted to SPA as provided in Section D (1) below. The final determination with respect to the classification will be made by SPA. D. Requirements Prior to or At Time of Protocol Submission 1. Submission of Documentation to SPA At the time that a PI submits a grant or contract proposal to SPA for a Sponsored Project that has one or more Subawards (or if the Subaward or Subrecipient is not known at the time of submission of a proposal, prior to the execution of the Subaward), he/she will provide SPA with the following documentation with respect to each Subrecipient: Subrecipient/Contractor Classification Form (attached hereto as Appendix A) Subcontract Proposal Face Page (attached hereto as Appendix B) If applicable, Justification for Subaward Exceeding 50% of Prime Award (attached hereto as Appendix C) If applicable, International Research Questionnaire (attached hereto as Appendix D). SOW Detailed Budget and Budget Justification. 2. Initial Actions by SPA and RPIC (a) SPA will determine if the University has entered into prior Subawards with the proposed Subrecipient. If so, SPA will check the University database (the Subrecipient Financial Database) maintained by RPIC to confirm that the Subrecipient has provided the documentation and has taken the actions required by the University and remains in good standing with the University. If the University (i) has never entered into a Subaward with the proposed Subrecipient or (ii) has entered into a Subaward with such Subrecipient, but such Subaward ended more than three years ago, SPA will notify RPIC and RPIC will obtain and review a completed Subrecipient Certification and Financial Status Questionnaire (attached hereto as Appendix E) and the documentation required by such Certification and Questionnaire. RPIC will enter the documentation relating to such review into the Subrecipient Financial Database. (b) If the aggregate amount payable under all Subawards in respect of the proposed grant or contract is expected to exceed 50% of the expected award thereunder, SPA will determine whether or not the proposal should be modified prior to its submission to the sponsor or withdrawn. SPA will notify the PI of its decision. If the PI disagrees with SPA s decision, he/she may appeal the matter to the Risk Review Committee, which will determine whether the proposal should be submitted (with or without modifications) or withdrawn. The Risk Review Committee s decision will be final. 4

5 (c) If the Subrecipient has not negotiated an indirect cost rate with the federal government, the parties will agree that the de minimis indirect cost rate (as defined in Section of the Uniform Guidance) or a rate set under specific sponsor guidelines shall be applicable to the Subaward. (d) SPA will provide the PI with a copy of the Principal Investigator Notification Regarding Subaward Monitoring Responsibilities. 3. Risk Assessment A proposed Subrecipient will be selected based on the assessment of the Subrecipient s ability to perform the SOW successfully. This includes (a) obtaining certain information from the proposed Subrecipient and (b) evaluating its risk of noncompliance with laws and regulations and the terms and conditions of the Subaward based on the Subrecipient s past performance, technical resources and financial viability. If the University (a) has never entered into a Subaward with the proposed Subrecipient or (b) has entered into a Subaward with such Subrecipient, but such Subaward ended more than three years ago, the Subrecipient will be subject to a formal risk assessment by SPA and RPIC. The risk assessment may take into account one or more of the following factors: Whether the Subrecipient and the Subrecipient PI are in good standing with the federal government; Whether the Subrecipient is organized or located in a non-u.s. jurisdiction;; The Subrecipient s current and past audit experience; The degree of external oversight of the Subrecipient by auditors or sponsor agencies; Evidence of effective accounting and procurement controls within the Subrecipient s systems and administrative operations; The size of the Subaward and the size of the Subaward relative to the prime award; Prior experience with the Subrecipient (e.g., pre-award negotiations, financial/operational reporting accuracy and timeliness, response to requests, etc.); The Subrecipient s organizational and individual conflicts of interest; and The risk category for the Subrecipient previously established by SPA and RPIC. Following the review of all necessary documentation, SPA will complete a Subaward Risk Assessment Questionnaire (attached hereto as Appendix F). If SPA categorizes the Subrecipient as high risk, it will notify RPIC, and SPA and RPIC will work with the PI to ascertain whether or not a Subaward should be issued, what special terms and conditions should be included in the Subaward, as well as what oversight requirements will be necessary to monitor the Subaward. SPA and RPIC are responsible for 5

6 ensuring that arrangements are in place to mitigate the risk to the University before issuing a Subaward. E. Establishment of Subaward Following the receipt of a notice of award and prior to the execution of the Subaward, the following actions must be taken: The Subaward Agreement will include the requirements imposed by the University on the Subrecipient so that the performance under the Subaward is carried out in accordance with all applicable laws and regulations and the terms and conditions of the award, and any additional requirements that Columbia imposes on the Subrecipient to meet its own responsibilities under the prime award, including the requirements that the Subrecipient permit the University and its auditor to have access to the Subrecipient s records and financial statements and that the Subaward include appropriate terms and conditions for closeout of the Subaward. If the award is funded by the Public Health Service, the PI shall submit to SPA a Follow Up Subrecipient FCOI Policy Confirmation Form or an Exception Form (attached hereto as Appendices G-1 and G-2), in each case if applicable. SPA shall confirm that the Subrecipient has provided evidence of IRB or IACUC approval, if applicable. SPA shall confirm the terms of the Subaward budget. SPA shall prepare and negotiate the Subaward. The Subaward must specify any financial and programmatic reports required of the Subrecipient in accordance with the Uniform Guidance. A Subaward will not be issued, nor payments to a Subrecipient authorized, prior to the University s receipt and acceptance of the prime award and the set up of the proper accounts in ARC. F. Post-Subaward Monitoring. 1. General. Following the execution of a Subaward, the PI and his/her Departmental Administrator (DA) will determine the frequency and scope of departmental monitoring procedures, provided that such procedures are not less than those required by the sponsor. 2. Performance. The PI is responsible for monitoring the activities of the Subrecipient to ensure that the Subaward is used for authorized purposes, in compliance with applicable laws and regulations and the terms and conditions of the Subaward, and that the Subaward performance goals are being achieved. Specifically, the following monitoring activities are appropriate actions to be undertaken by the PI and DA: Reviewing financial and programmatic reports required by the Subaward on a timely basis. Receiving informal progress reports by telephone or , provided that any telephonic reports are documented; 6

7 Performing site visits if practical to evaluate the Subrecipient s compliance with the scientific objectives of the Sponsored Project and the appropriateness of the Subrecipient s administration of the Subaward. The frequency such site visits will depend on the risks associated with the Subaward, the level of complexity of the activity and the scope and duration of the projects. Site visits should be documented by meeting notes, trip reports or correspondence; and/or Following up and ensuring that the Subrecipient takes timely and appropriate action with respect to deficiencies pertaining to the award detected through progress reports, audits, on-site reviews and other means. Copies of materials received by the PI or DA in connection with his/her monitoring responsibilities should be retained in the Department s files. The Subrecipient s progress should be included in the PI s report to the sponsor. The PI or DA should report any material problems with respect to the Subaward to SPA. SPA will coordinate with the appropriate personnel in the Office of the Controller with respect to a response. 3. Invoices. The PI and the DA will review Subrecipient invoices prior to authorizing their payment. Subrecipient invoices should contain at least the following information: The period of performance covered by the invoice; A description of expenses itemized by major budget categories); Current period costs, including cost sharing (in sufficient detail to enable comparison to the project budget); Cumulative project costs, including cost sharing, as compared to the project budget; Subrecipient contact person with respect to the invoice; and Certification as to the accuracy and appropriateness of the expenses. Evidence of regular review of invoices by the PI and the DA must be retained in the Department s files. Evidence can be in the form of PI initials or authorizing signatures on invoices, communications, meeting notes, etc. If after review of any invoice, a concern with respect to the Subrecipient s performance or the inclusion of unusual, excessive or unexplained charges is identified, the PI or the DA should request clarification from the Subrecipient. If the explanation from the Subrecipient is not sufficient to render a prudent judgment on the allowability of the cost or compliance with the terms of the Subaward, the PI or the DA should notify SPA and Sponsored Project Finance (SPF) as soon as possible. SPA and SPF will review the matter. Examples of detailed justifications that may be requested include: Payroll records/data; 7

8 Copies of paid invoices showing the cost of items purchased or Vendor Justification Forms if required by federal law; Descriptions of services rendered by consultants, including hourly rates and time reports; and Details of travel charges (air fare, meals, ground transportation) with purposes of travel stated. Unreasonable, unallowable or unallocable costs should be disallowed by the PI, the DA or SPF. The DA should document the reason for the disallowance (i.e., progress reports not filed, expenses not in line with the SOW, etc.) and contact the Subrecipient to issue a revised invoice. Copies of invoices should be retained in the Department s files. The PI shall have the right to request random audits of invoices under a Subaward from time to time during the term of the Subaward. Within 45 days following the close of each fiscal quarter, the PI must confirm in writing that he/she has reviewed such fiscal quarter s expenditures associated with each Sponsored Project of which he/she is the PI and that the expenditures are allowable and appropriate for such Project. Copies of the attestation statement will be retained in the Department s files. 4. Annual Monitoring. On an annual basis, RPIC will ensure that an Annual Subrecipient Certification and Financial Status Questionnaire (attached hereto as Appendix H) is completed by each Subrecipient listed in the Subrecipient Financial Database that is a party to an active Subaward. RPIC will follow up in a timely fashion with any Subrecipient that does not provide it with the required information described above. In the event that the Subrecipient fails to respond, RPIC may determine that subsequent invoice from such Subrecipient should not be paid until such actions are taken. If such determination is made, RPIC shall so notify SPA and SPF. RPIC will update the Subrecipient Financial Database to record the receipt (or non-receipt) of the information described above and, based on its assessment of the findings and the corrective action plan, make a determination whether the Subrecipient is currently high risk. In certain cases, RPIC may determine that the Subrecipient s non-compliance with the University s requirements is so serious and the risks of continuing the Subaward are so high that the Subaward should be terminated. G. Closeout Following the conclusion of a Subaward period of performance, Subaward should be processed for closeout and formally closed within 60 days, unless SPA grants the PI an 8

9 extension of time. The following requirements must be met prior to a Subaward being closed out: The PI should insure that all deliverables (e.g., technical/progress reports, patent/invention documentation, equipment reports, final invoice, etc.) have been received from the Subrecipient and should verify the technical completion of the Sponsored Project. The PI, with the assistance of his/her DA, should complete a final review of all costs charged by the Subrecipient to insure that only allowable and appropriate costs have been incurred. Once the above tasks have been completed, the PI should approve the final invoice from the Subrecipient, indicating that it represents a final payment. Such approval will represent the PI s acknowledgement that all tasks and obligations of the Subrecipient have been completed. It is important that the final invoice be promptly received and approved, in order to insure appropriate and timely expenditure reporting to the sponsor. If the actual costs incurred by the Subrecipient are less than the maximum amount authorized by the Subaward (and the purchase order authorizing the commitments of funds to the Subrecipient), the PI and/or the DA will advise SPF to close out the remaining commitment on the purchase order. 9

10 Subrecipient/Contractor Classification Form Principal Investigator Name: Name of Subrecipient/Contractor Entity: Title of Sponsored Project: Sponsor: Rascal Proposal Tracking (PT) #: Instructions: Check all boxes in both columns that best describe the relationship with the subrecipient/contractor entity. The column with the greatest number of likely indicates the classification of the subrecipient/contractor entity. Additional guidance is available on page two. Note: In determining whether Columbia University and another entity have a subrecipient relationship or a contractor relationship, the substance of the relationship is more important than the form of the agreement. All of the characteristics listed below may not be present in all cases, and judgment must be used in classifying each agreement as a subaward or a procurement contract. In the event there are questions relating to classifying a resource, please contact your SPA Project Officer for assistance. Column A: SUBRECIPIENT Characteristics A subaward is issued for the purpose of carrying out a portion of a prime award. Columbia University (within the sponsor s guidelines) determines who is eligible to receive the subaward The entity s performance will be measured in relation to whether objectives of the prime award are met The entity has responsibility for programmatic decision making The entity uses the funds to carry out a program for a public purpose, as opposed to providing goods or services for the benefit of Columbia University Column B: CONTRACTOR Characteristics A contract (or other type of vendor agreement) is for the purpose of obtaining goods and services for Columbia University s own use, and is a procurement relationship. The entity provides the goods and services within normal business operations The entity provides similar goods or services to many different purchasers The entity normally operates in a competitive environment The entity provides goods or services that are primarily for the benefit of Columbia and only indirectly might support the operation of a federally sponsored project. Entities that include these characteristics are responsible for adherence to applicable program requirements and terms and conditions as specified in the prime sponsored award. Optional Explain any reasoning for your determination, if desired: Entities that include these characteristics are not subject to compliance requirements of the prime sponsored as a result of the agreement, similar requirements may apply for other reasons. DETERMINATION (check one): SUBRECIPIENT PI Signature: CONTRACTOR Date: //2015 Ver. 1.0

11 Additional Guidance on Differentiating Between a Subrecipient and a Contractor Subrecipient The legal entity to which a subaward is made and which is accountable to the prime recipient for the use of the funds provided. An entity receiving a portion of the funds from a sponsored project is considered to be a subrecipient if it: Has programmatic involvement in the project identified by a separate scope of work, a separate budget and separate organization approval; Conducts substantive work (effort that engages directly in carrying out specific aims of the prime award); Has a director of the subaward who is considered the principal investigator (PI), and who may be considered a co-pi on the sponsored project with the PI at the prime institution; Has responsibility for programmatic decision-making; Has responsibility for adherence to applicable program compliance requirements (i.e. IRB/IACUC approvals, FCOI policies, etc.); Uses the sponsored funds to carry out the project at its institution as compared to providing goods or services for the project at Columbia University; Has the right to publish project results or serve as a co-author; and Has potentially patentable or copyrightable technology and intellectual property (IP) resulting from the project. Subawards are Sponsored Projects Administration (SPA) Consultant An individual or company receiving a portion of the funds from the sponsored project is considered a consultant if he/she/it: Is an expert advisor; Is paid for time spent on a fixed hourly/daily basis, which includes travel expenses, supplies, etc.; Is using his/her/its own equipment and materials, not equipment or materials from his/her/its institution, for the work on the project; Is providing services that are specialized, highly technical, and commercially available; Is considered to be paid a fee for service whose work and IP belong to Columbia University; Pays his/her own taxes on earnings from the project; Is not employed by Columbia University in any other capacity; and/or Is not involved in programmatic work on the project; including project deliverables such as reports. *Note Consultants may be considered Non-key Personnel, Other Significant Contributors, or, rarely, Key Personnel, on a sponsored project. P must carefully review the role of the consultant to make this determination. Vendor/Service Provider An individual or company receiving a portion of the funds from a grant award is considered a vendor if he/she/it: Provides goods and/or services ancillary to the project; Is paid a flat fee; Provides similar goods or services to many different customers; and/or Is not involved in programmatic work on the project, including project deliverables such as reports. Consultants and Vendors/Service Providers are processed through the Purchasing Department. For more information, go to //2015 Ver. 1.0

12 Appendix B The Trustees of Columbia University in the City of New York SPONSORED PROJECTS ADMINISTRATION SUBCONTRACT PROPOSAL FACE PAGE PRIME INSTITUTION Legal/Corporate Name SUBCONTRACT INSTITUTION Legal/Corporate Name The Trustees of Columbia University in the City of NY Principal Investigator: Principal Investigator: Department: Department: Medical Center: 630 West 168th Street, Box 49 Address: New York, NY City: State: Zip: Ph: (212) Fax: (212) Phone#: EIN # DUNS #: EIN #: Morningside: 615 West 131st Street DUNS #: New York, NY For Profit: Non Profit: Fiscal Year End: Ph: (212) Fax: (212) EIN # DUNS #: FCOI Policy: Y N Prime Funding Sponsor: Title of Project: Dates of Proposed Project Period: Dates of Initial Budget Period: Estimated Total Costs (Direct and Indirect): First Year Direct: $ First year Indirect: $ Total: $ Project Total Direct: $ Project Total Indirect: $ Project Total: $ Human Research Subjects: Y N IRB Approval: Pending Approval Date: Laboratory Animals: Y N IACUC Approval: Pending Approval Date: Fixed Price Subaward: Y N Cost Reimbursement Subaward: Y N Per Patient Subaward: Y N Cost per Patient: $ AUTHORIZED COLUMBIA UNIVERSITY OFFICIAL: Name: Title: Address: Address: Telephone Number: We agree to abide by the prime sponsor s policies and are prepared to negotiate the necessary inter-institutional agreements consistent with those policies. SIGNATURES: Principal Investigator: Date: Authorized Official: Date: Revision date: March 2015

13 Send Form By To: Morningside: or CUMC: In accordance with federal regulations, it is University policy that the University awardee must perform a substantive role in carrying out the activities of a project and not merely serve as a conduit for an award to another party. It is expected that the aggregate amount payable under all Subawards in respect of any award made to the University should not exceed 50% of such award without the prior approval of the Subaward Committee. PI Name: RASCAL #: Date of Form: Proposal Due Date: Please provide a brief statement of work for the overall project: Please provide a brief statement of work for each subaward: Explain why the subaward(s) perform a substantive role in carrying out the activities of the project (50% or more of the overall project). How will the CU PI coordinate and manage the work at the subcontract site that is doing the bulk of the work? Subaward Name Direct Cost Indirect Cost Total Cost TOTAL CU Cost Direct Cost Indirect Cost Total Cost (excluding subaward cost) Project Cost Direct Cost Indirect Cost Total Cost CU plus Subawards Version.0

14 Appendix D International Research Questionnaire 1. Which non-u.s. countries do you expect to involve in your project? 2. How long is the proposed grant period? 3. What is the annual dollar amount of the grant and the source of funding? Are any local funds to be used in the conduct of the project? 4. What activities do you expect to be involved in? 5. Do you expect to have CU employees or students located in a non U.S. country? If so, (a) what will they be doing, and (b) how long will each be located in the non-u.s. country? 6. Will you have a local collaborator (either in the form of a local sponsor or subcontractee)? If so, what will they be doing? Will they be compensated? If so, how do you plan to compensate them? 7. Do you plan to (a) hire local employees in the project, (b) open local bank accounts or (c) enter into leases or other contracts for goods and services? 8. Will the project involve human subjects or recipients of services? If so, how will they be used or what services will be provided? Are there any vulnerable populations impacted? 9. Have you had any previous projects in the non-u.s. country in which your proposed project will be located? If so, what was the nature of the project and were there any problems that arose? 10. Are you aware of any other CU projects in the non-u.s. country in which your proposed project will be located? If so, please identify. 11. What are the principal risks relating to the project that should be addressed?

15 Appendix E Office of the Controller Research Policy and Cost Analysis 615 West 131 st Street New York, NY Dear Sir or Madam: We have been informed that Columbia University has submitted a proposal to a sponsor in which your institution has been named as a subrecipient. Accordingly, to ensure that your institution is in compliance with the Federal Office of Management and Budget (OMB), Circular A-133 and the Uniform Guidance, Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Columbia University requires that the attached Subrecipient Certification and Financial Status Questionnaire, together with all required documentation, be completed and returned as soon as possible to Failure to respond or provide the required information could result in non-issuance of the subaward. If you have any questions, please contact Sincerely, Signed/ Carl Sparano Carl Sparano Executive Director, Research Policy and Cost Analysis Tel (212) / Fax (212)

16 SUBRECIPIENT CERTIFICATION Please note: In lieu of a copy of a document, a URL may be provided. A. Subrecipients subject to OMB Circular A-133 (A-133) or Uniform Guidance (UG) Audit Requirements: State or Local Governments/Agencies or Non-Profit Organizations. We have completed our A-133 or UG audit for FY.The audit disclosed no findings of material weaknesses, material instances of noncompliance, and/or questionable costs. A copy of the A-133 or UG audit report, together with the auditor's management letter, must be returned with this certification or transmitted via the following URL: We have completed our A-133 or UG audit for FY. The audit disclosed findings of material weaknesses, material instances of noncompliance, and/or questionable costs. A copy of the A-133 or UG audit report, together with the auditor's management letter and a corrective action plan describing the steps taken to resolve the non-compliance issues, must be returned with this certification or transmitted via the following URL: We have not yet completed our A-133 or UG audit for FY, which ended on. We expect the audit to be completed by. Upon completion, we will forward an updated copy of this certification, together with the appropriate documentation. B. Subrecipients Not Subject to A-133 or UG Audit Requirements. We are not subject to the A-133 or UG audit requirements for FY because: For A-133 subrecipients, we expended less than $500,000 in Federal funds. For UG subrecipients, we expended less than $750,000 in Federal funds. We are a for-profit organization. We are a non-u.s. entity. Other. Please provide an explanation: 1. Subrecipients Not Subject to A-133 or UG Audit Requirements With Audited Financial Statements. Our financial statements for FY have been audited by an independent auditor. A true and complete copy of the audit report, together with the auditor s management letter, is enclosed. If the audit disclosed findings of material weaknesses, material instances of noncompliance, and/or questionable costs, a corrective action plan describing the steps taken to resolve the findings must be returned with this certification or transmitted via the following URL: 2. Subrecipients Not Subject to A-133 or UG Audit Requirements Without Audited Financial Statements. Our financial statements for FY have not been audited by an independent auditor. A true and complete copy of such financial statements is enclosed.

17 C. To Be Completed By All Subrecipients Have you received a letter from your cognizant Federal audit resolution authority indicating acceptance of management's response for action taken to correct noncompliance issues? If so, please provide a copy of the most recent acceptance letter with this certification. Have you received a letter from your cognizant Federal audit resolution authority indicating an unsatisfactory response to management's plan to correct non-compliance issues? If so, please explain the status of the audit resolution and provide a copy of the letter with this certification. Have you been notified by any Federal, state or local government agency of debarment or pending debarment from receiving Federal monies either directly or as a subrecipient? If so, please provide a copy of the notification letter with this certification. D. Certification: I certify that the information provided herein is true and correct to the best of my knowledge. Print Name Signature Date Title Institution Address Department Phone Fax Fiscal Year EIN Number DUNS Number Not-For-Profit For Profit Domestic Foreign

18 FINANCIAL STATUS QUESTIONNAIRE All Subrecipients are required to complete this Financial Status Questionnaire General Information Has any aspect of your organization s activities other than its financial statements been audited within the last two years by a governmental agency or independent public accountant? If so, please provide a copy of any such audit report. Are duties in your organization separated so that no one individual has complete authority over an entire financial transaction? Does your organization have controls to prevent expenditure of funds in excess of approved budgeted amounts? Does your organization maintain current, accurate information on the Central Contractors Registration (CCR) website ( What is the current registration expiration date? Cash Management Are all of your organization s disbursements properly documented with evidence of receipt of goods or performance of services? Are all of your organization s bank accounts reconciled monthly? Payroll Are all of your organization s payroll charges checked against program budgets? What system does your organization use to control paid time, especially time charged to sponsored agreements? Procurement Are there procedures in your organization to ensure procurement at competitive prices? Is there an effective system of authorization and approval in your organization of: a) Capital equipment expenditures? b) Travel expenditures?

19 Property Management Are detailed records of individual capital assets in your organization kept and periodically balanced with the general ledger accounts? Are there effective procedures in your organization for authorizing payment and accounting for the disposal of property and equipment? Are detailed property records in your organization periodically checked by physical inventory? Briefly describe your organization s policies concerning capitalization and depreciation: Cost Transfers How does your organization ensure that all cost transfers performed are legitimate and appropriate? Indirect Costs/Fringe Benefits Does your organization have an indirect cost allocation plan or a negotiated indirect cost rate with the Federal government? Does your organization have a negotiated fringe benefit agreement? If so, please provide copies of the most recent negotiated indirect cost rate and fringe benefits rate agreements. If none exist, please describe the process for determining that your organization charges Columbia indirect costs and fringe benefit expenses at its most favorable rates. Does your organization have procedures that provide assurance that consistent treatment is applied in the distribution of charges to all grants, contracts and cooperative agreements? Please summarize the procedures, or provide the URL for these documents. Cost Sharing How does your organization determine that it has met cost sharing goals?

20 Compliance Does your organization have a formal policy of nondiscrimination and a formal system for complying with United States Federal civil rights requirements? Does your organization have a cash forecasting process that will minimize the time elapsed between the drawing down of funds and the disbursement of those funds? If your organization enters into agreements for work or research to be performed outside of the United States, does it have systems in place to prevent and detect payments made to government officials to allow or procure work and research opportunities for or on behalf of your organization? Documents provided: Indirect Cost Rate Agreement URL Fringe Benefit Agreement URL Certification: I certify that the information provided herein is true and correct to the best of my knowledge. Print Name and Title Institution Signature Date

21 COLUMBIA UNIVERSITY SUBRECIPIENT RISK ASSESSMENT QUESTIONNAIRE Appendix Subrecipient Institution: DUNS: Prime Principal Investigator: Prime Sponsor: Project ID: If the response to any of the questions below is YES the subrecipient is considered a High Risk entity. Please notify RPIC. YES NO 1. Is the subrecipient institution currently debarred or suspended? Y N 2. Is the subrecipient Principal Investigator currently debarred or suspended? Y N 3. Does the subrecipient institution appear in SAM with the federal debt flag? Y N 4. Has it been determined that the subrecipient institution does not have a compliant PHS Financial Conflict of Interest Policy? Y N 5. Has it been determined that the subrecipient institution does not have an established accounting system? Y N 6. Has it been determined that the subrecipient institution does not have an acceptable procurement system? Y N 7. Is there a management decision on audit findings that may affect this award? Y N 8. Is cost share required or included? Y N 9. Did the most recent audit under A-133/Uniform Guidance or similar result in unsatisfactory findings? Y N 10. Is the subrecipient institution a foreign entity? Y N 11. Do the total outgoing funds exceed $750, 000? Y N 12. Does the percentage of the prime award being subcontracted exceed 50%? Y N 13. Have other risks been identified? Y N COMPLETED BY: DATE COMPLETED: DATE NOTIFIED RPIC:

22 COLUMBIA UNIVERSITY SPONSORED PROJECTS ADMINISTRATION FOLLOW-UP SUB-AWARDEE FCOI POLICY CONFIRMATION FORM Project Title: Proposed Sponsor: Columbia PI: Sub PI: Sub Institution: In accordance with U.S. Public Health Service (PHS) regulations on financial conflict of interest in research, Columbia University (the University ) requires disclosure of financial conflicts of interest by its PHSfunded subcontractors and award subrecipients. Should the application named above be funded, your institution will participate in this research project as a subrecipient in relationship with Columbia. Your institutional official s signature below serves as confirmation that your institution has a conflict of interest policy and process which conforms to the requirements of PHS regulations set forth in 45 CFR Part 94 and 42 CFR Part 50, Subpart F, Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought as amended in Your institutional official s signature confirms that your institution has: (i) (ii) (iii) implemented the requisite conflict of interest policy; collected and reviewed disclosure forms from all relevant investigators for this project; and reported any conflicts to the University. If you are unable to complete this confirmation, you must immediately submit an explanation to (Medical Center) or at (main campus) but your institution may not qualify to be a subrecipient for this project. This confirmation is required prior to the commencement of any work at your site and the release of any subaward funds to you. If you do not have the required conflict of interest policy in place, the University may not issue a subaward to your institution. Should you need additional information, please contact our office by via at (Medical Center) or at (main campus). Accepted and confirmed by / Signature of Authorized Signing Official Date Title of Authorized Signing Official Print Name of Authorized Signing Official / Address 8/17/2012

23 COLUMBIA UNIVERSITY SPONSORED PROJECTS ADMINISTRATION SUB-AWARDEE FINANCIAL CONFLICT OF INTEREST POLICY EXCEPTION REQUEST This is a request to allow the above subrecipient to be subject to Columbia University s Policy on Financial Conflicts of Interest and Research, revised effective Aug. 24, 2012, to fulfill the requirements of Public Health Service Regulations entitled Responsibility of Applicants for Promoting Objectivity in Research for which PHS Funding is Sought, 42 CFR Part 50 Subpart F ( PHS Regulations ), as amended Aug. 24, You must complete all of the information below for consideration by the Office of the Executive Vice President for Research. Completed forms should be sent to Sponsored Projects Administration via at (CUMC) or at (MS & Lamont). Project Title: Sponsor: Sponsor Award Number: Columbia PI: Sub PI: Sub Institution: Sub Institution Address: Anticipated Start Date of Project: Anticipated Period of Subawardee Involvement: 6/14/2013

24 COLUMBIA UNIVERSITY SPONSORED PROJECTS ADMINISTRATION SUB-AWARDEE FINANCIAL CONFLICT OF INTEREST POLICY EXCEPTION REQUEST 1. Description of project, including role of subrecipient. 2. Identity and role of subrecipient investigators who will work on this project. Please note that investigator is defined as: the Project Director/Principal Investigator and any other individual, regardless of title or position, who is responsible for the design, conduct, or reporting of research funded by the PHS, or proposed for such funding. This term is not intended to include individuals who are purely advisory or are not sufficiently independent to be in a position to influence design, conduct or results of such Research. a. Name Role b. Name Role c. Name Role d. Name Role e. Name Role f. Name Role [Please add additional if needed] 6/14/2013

25 COLUMBIA UNIVERSITY SPONSORED PROJECTS ADMINISTRATION SUB-AWARDEE FINANCIAL CONFLICT OF INTEREST POLICY EXCEPTION REQUEST 3. Justification for why the proposed subrecipient is uniquely qualified to carry out the proposed scope of work and cannot be replaced by an organization with its own Financial Conflict of Interest policy in compliance with PHS regulations: 4. Subrecipient s plan for developing and implementing an FCOI Policy in compliance with PHS Regulations, including estimated time by which subrecipient will be in compliance: 6/14/2013

26 Appendix H Office of the Controller Research Policy and Cost Analysis 615 West 131 st Street New York, NY Dear Sir/Madam: Our records indicate that your institution was a subrecipient of funds awarded to Columbia University. Accordingly, to ensure that your institution is in compliance with the Federal Office of Management and Budget (OMB), Circular A-133 and the Uniform Guidance, Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Columbia University requires that the attached Annual Subrecipient Certification and Financial Status Questionnaire, together with all required documentation, be completed and returned to within thirty (30) days from receipt of this letter. Failure to respond or provide the required information could result in nonpayment of invoices and/or termination of the subaward(s). If you have any questions, please contact Sincerely, Signed/Carl Sparano Carl Sparano Executive Director, Research Policy and Cost Analysis Tel (212) / Fax (212)

27 ANNUAL SUBRECIPIENT CERTIFICATION Please note: In lieu of a copy of a document a URL may be provided A. Subrecipients subject to OMB Circular A-133 (A-133) or Uniform Guidance (UG) Audit Requirements: State or Local Governments/Agencies or Non-Profit Organizations. We have completed our A-133 or UG audit for FY. The audit disclosed no findings of material weaknesses, material instances of noncompliance, and/or questionable costs relating to any subaward(s) received from Columbia University. A copy of the A-133 or UG audit report, together with the auditor's management letter, must be returned with this certification or transmitted via the following URL: We have completed our A-133 or UG audit for FY. The audit disclosed findings of material weaknesses, material instances of noncompliance, and/or questionable costs relating to any subaward(s) received from Columbia University. A copy of the A-133 or UG audit report, together with the auditor's management letter and a corrective action plan describing the steps taken to resolve the non-compliance issues, must be returned with this certification or transmitted via the following URL: We have not yet completed our A-133 or UG audit for FY, which ended on, the period during which the subaward(s) received from Columbia University was active. We expect the audit to be completed by. Upon completion, we will forward an updated copy of this certification, together with the required documentation. B. Subrecipients Not Subject to A-133 or UG Audit Requirements. We were not subject to the requirements of A-133 or UG audit for FY because: For A-133 subrecipients, we expended less than $500,000 in Federal funds. For UG subrecipients, we expended less than $750,000 in Federal funds. We are a for-profit organization. We are a non-u.s. entity. Other. Please provide an explanation: 1. Subrecipients Not Subject to A-133 or UG Audit Requirements With Audited Financial Statements Our financial statements for FY have been audited by an independent auditor. A true and complete copy of the audit report, together with the auditor s management letter, is enclosed. If the audit disclosed findings of material weaknesses, material instances of noncompliance, and/or questionable costs relating to any subaward(s) received from Columbia University, a corrective action plan describing the steps taken to resolve the findings must be returned with this certification or transmitted via the following URL: 2. Subrecipients Not Subject to A-133 or UG Audit Requirements Without Audited Financial Statements Our financial statements for FY have not been audited by an independent auditor. A true and complete copy of such financial statements is enclosed.

28 C. To Be Completed By All Subrecipients Have you received a letter from your cognizant Federal audit resolution authority indicating acceptance of management's response for action taken to correct noncompliance issues? If so, please provide a copy of the most recent acceptance letter with this certification. Have you received a letter from your cognizant Federal audit resolution authority indicating an unsatisfactory response to management's plan to correct non-compliance issues? If so, please explain below the status of the audit resolution and provide a copy of the letter with this certification. Have you been notified by any Federal, state or local government agency of debarment or pending debarment from receiving Federal monies either directly or as a subrecipient? If so, please provide a copy of the notification letter with this certification. D. Certification: I certify that the information provided herein is true and correct to the best of my knowledge. Print Name Signature Date Title Institution Address Department Phone Fax Fiscal Year DUNS Number EIN Number Not-For-Profit For Profit Domestic Foreign