Juanita Syljuberget Alabama Cooperative Extension System May 23, 2012

What is a Subaward? “Subaward means an award of financial assistance in the form of money, or property in lieu of money, made under an award by a recipient to an eligible subrecipient or by a subrecipient to a lower tier subrecipient. The term includes financial assistance when provided by any legal agreement, even if the agreement is called a contract, but does not include procurement of goods and services nor does it include any form of assistance which is excluded from the definition of “award” in paragraph (e).” OMB Circular A-110, Subpart A, ___.2 Definitions, (ff)

When to Write a Subaward When a portion of the project is going to be carried out at another institution or organization where the third party is required to provide the necessary resources to conduct the work, including an investigator. Third party budgets could include: labor, employee benefits, materials and supplies, travel, equipment, subcontracts, consultants, other direct costs, indirect costs, and non-construction activities. Usually requires Sponsor approval

OMB A-133 Compliance Supplement, Part 3 – Compliance Requirements, Section M. Subrecipient Monitoring ars_default

A Pass-Through Entity is Responsible For: Determining Subrecipient Eligibility Central Contractor Registration (CCR) – if ARRA funds Award Identification During-the-Award Monitoring Subrecipient Auditing Ensuring Accountability of For-Profit Subrecipients Pass-Through Entity Impact

During-the-Award Monitoring Factors that may affect monitoring: Program Complexity Percentage Passed Through Amount of Awards Subrecipient Risk

During-the-Award Monitoring Monitoring Activities Reporting Site Visits Regular Contact Agreed-upon Procedures Engagements

subagreements.aspx

Required at Proposal Stage Legal Name of Subrecipient Contact Name and Address – PI and Administrative Tax ID # and DUNS # for Subrecipient Subrecipient’s Scope of Work Subrecipient’s itemized budget/budget justification Subrecipient’s qualifications to perform the work Letter of Commitment Sponsor certifications/requirements, if applicable

At the Award Stage  The OSP Contract Administrator (CA) will process the prime award then send it to Contracts & Grants Accounting (CGA) for account set-up.  CA notifies the Subagreement Administrator (SA) of the Subagreement  SA requests additional required documentation from Subrecipient or AU Principal Investigator (PI), if necessary

At the Award Stage  SA completes desk audit of subrecipient  EPLS Website  Single Audit Database  F&A Rate Agreement  Subagreement draft is sent for PI approval  Following PI approval, Subagreement is sent to Subrecipient

EPLS – Excluded Parties List System “This World Wide Web site is provided as a public service by General Services Administration (GSA) for the purpose of efficiently and conveniently disseminating information on parties that are excluded from receiving Federal contracts, certain subcontracts, and certain Federal financial and nonfinancial assistance and benefits, pursuant to the provisions of 31 U.S.C. 6101, note, E.O , E.O , 48 CFR 9.404, and each agency's codification of the Common Rule for Nonprocurement suspension and debarment.”

Single Audit Database The Federal Audit Clearinghouse (FAC) database consists of information about Single Audits of Federal awards as required by Office of Management and Budget (OMB) Circular A-133 (Revised June 27, 2003).

Certification Letter Must be completed each fiscal year for the duration of the Subagreement If there are material noncompliance issues and/or reportable conditions noted or there are findings that are specifically related to a prime award from Auburn University within the OMB Circular A-133 audit, the audit report must be reviewed by the SA. If necessary, the SA will follow up with Subrecipient to ensure corrective action plans have been implemented. Subrecipients that do not expend $300,000 or more in Federal awards and are not subject to the requirements of OMB Circular A-133 must provide an audit report or financial statements.

Facilities & Administration Cost Rate Agreement A current F&A Cost Rate Agreement is requested from the subrecipient F&A Cost Rate Agreements are imported into Xtender New F&A Cost Rate Agreement will be requested upon expiration of the agreement on file

Full Execution of Subagreement  SA receives signed Subagreement from Subrecipient and obtains AU institutional signature  SA sends request to Payment and Procurement Services (PPS) to create Encumbrance. PI and Department Contact will be notified with the Encumbrance number.  Fully executed Subagreement is mailed to Subrecipient, AU PI and CGA

Subagreement Modifications OSP will obtain PI’s approval of requested changes and issue a subagreement modification and/or modify the encumbrance accordingly The modification will only address the specific terms of the original Subagreement to be modified. All other terms and conditions of the Subagreement will remain in effect and unchanged

PI/Dept Invoicing Procedures Per Subagreement, invoices are mailed to the PI Invoices require PI approval before sending to OSP for processing PI ensures that the Subrecipient:  Meets the expectations outlined in the Subagreement’s Scope of Work and Budget  Submits required Technical Reports  Submits sufficient cost-sharing statements (if applicable)  Submits Final Close Out Documents

OSP Invoicing Procedures Verify invoice period of performance dates are within the period of performance of the Subagreement Compare balance of OSP Subagreement database with balance of the encumbrance Confirm vendor number, account number, and invoice amounts on the vendor voucher Invoice information is logged into the Subagreement database Invoice is scanned into Xtender Original invoice is sent to PPS for payment

Close Out Requirements Final progress report received – sent to PI Close Out Document completed, reviewed and approved by PI Final invoice – will not be processed until OSP receives approved Close Out Document

Subagreement Website

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