Subaward Life Cycle 10/24/17

Agenda Important Definition Life of a sub-award Resources Pre-award Post Award Closeout Resources Subaward process: http://www.bc.edu/content/dam/files/research/osp/SUBAWARDPROCESS.pdf

Definitions Subaward Contractor (Vendor) Provides a significant portion of the programmatic effort Retains rights to IP Is responsible to adhere to all applicable federal compliance Is usually another higher ed. Institution, hospital or other non profit organization Contractor (Vendor) Provides goods or services to many different businesses Normally operates in a competitive environment Is not subject to compliance of the federal program Can be a company or an individual

Proposal Preparation Stage Pre-Award Award Post-Award Closeout Proposal Preparation Stage

Department/PI: Pre-Award Sub Notify OSP of upcoming proposal and provide RFP PI requests proposal package from proposed subrecipient, to include: Required: Statement of Work, Detailed Budget, Budget Justification, Subrecipient Commitment Form, Other documents as required by Sponsor Recommended: Subrecipient F&A Rate Agreement and Subrecipient Fringe Benefits Rate Agreement To be conducted by OSP: Audit/Financial Status verification and Subrecipient Risk Analysis If applicable: Human subjects and/or Animal subjects approval docs Subaward checklist available online: http://www.bc.edu/content/dam/files/research/osp/SubawardChecklist.pdf Sub commitment form: http://www.bc.edu/content/dam/files/research/osp/SubrecipientCommittmentForm.pdf The initial award stage, for the purposes of this policy is a stage that includes both proposal development through award set-up. The goal of subrecipient monitoring efforts at this stage is to ensure that the subrecipient is capable of compliantly spending the funds and meeting the project goals. Subrecipient completes the Subrecipient Commitment Form which provides an initial assessment of their ability to manage funds.

Department/PI: Proposal with Subs Proposal with a subaward include the following: Subrecipient proposal into BC full proposal Subrecipient’s budget total as a single direct cost line item in BC budget IDC is applied to the first $25K of each sub Other forms (e.g, budget, biosketches, other support) as required by BC’s sponsor Forward completed BC proposal to OSP Rep for review Subaward checklist available online: http://www.bc.edu/content/dam/files/research/osp/SubawardChecklist.pdf

Office of Sponsored Programs: Pre-award Review RFP and agency/foundation requirements Complete Sub Review to include Letter of Commitment Statement of Work Budget and Budget Justification F&A Rate Agreement Confirm they can adhere to prime guidelines and has a financial conflict of interest policy in place

Pre-Award Award Post-Award Closeout Award Stage

Department/PI: Proposal Awarded Once, OSP notifies department of award: Department submits the Subaward Initiation Request Form and the supporting documentation to OSP Upon receipt of signed agreement, Department works with Purchasing to initiate the issuance of a Purchase Order Subaward initiation form: http://www.bc.edu/content/dam/files/research/osp/DepartmentalSubawardInitiationRequestForm.pdf

OSP: Award Stage OSP notifies department of award Dept. sub initiation form is received Obtain completed subrecipient questionnaire Obtain completed commitment form Determine financial adequacy of the sub recipient Obtain evidence of most recent F&A rate agreement Verify the subrecepient is not on debarred list Complete risk assessment Red flags: History of noncompliance, new to the efforts, etc.)

Potential Indicators of High-Risk A qualified audit report, or failure to have a current audit report Inadequate response to a financial questionnaire History of non-compliance History of non-performance or failure to use funds for their authorized purposes New subrecipient (or new to this type of project)

to High Risk Sub-recipients Potential Resolution to High Risk Sub-recipients Discuss need for special monitoring with PI/department Ask for extra contact between PI and Sub’s PI Ask for more frequent technical/financial reporting Add more detailed or frequent invoicing requirements Add requirement for expenditure backup materials Tie receipt of technical progress reports to payments Require on-site monitoring (technical and financial) Add more stringent termination language for failure to comply with requirements

Preparing the Sub-Award

OSP: Preparing Sub-Award Statement of Work Key Personnel Period of Performance Dollar Amount Payment Terms Prior Approvals Cost Sharing Reporting Requirements Intellectual Property Flow down requirements

Monitoring an Active Sub-award

Pre-Award Award Post-Award Closeout Post-Award

OSP: Subaward Monitoring Communicate problems with OSP on reporting/deliverables Annual review of active subs Single audit handled by OSP Compliance Review Audit clearinghouse Follow up with sub with any issues Maintain the subrecipient risk assessment process

Department/PI: Subaward Monitoring PI monitors subrecipient technical progress Communicate regularly with subrecipient PI to monitor progress on the project Monitor receipt of technical reports for timeliness and content Communicate with OSP if changes need to be made to work statement, reporting requirements, budgeting. PI/Department monitors subrecipient’s adherence to terms

Department/PI: Subaward Monitoring PI/Department reviews invoices Are they arriving on schedule? If not, PI/Department contacts subrecipient for invoices Do they contain the right level of detail to allow adequate review, and are they in accordance with the agreement? Ensures all costs are allowable, allocable and reasonable Ensures all costs were incurred within the period of performance of the subaward Confirms that expenses are aligned with technical progress Cost sharing is appropriately reflected, if required If acceptable, PI signs and dates invoice PI/Department sends invoice to Procurement Services for processing PI/Department reviews Transaction Detail Report (TDR) to verify that approved invoices appear on the project From last month’s BRIEF: • Invoice lists detailed accounts / costs • Invoiced costs are in the approved agreement budget – NO DEVIATIONS • Recalculate invoice including fringe and F&A costs • Total expenses for sub < total amount obligated to date • Ensure costs are incurred during the correct budget period • Ensure the following are on the sub’s invoice: BC project number; costs are in US dollars; dates of costs/services • Ensure subs submit invoices timely especially near closeout • If questions/concerns, discuss with sub (also OSP as needed) • PI/Dept stamp - PI signature with date

Department/PI: Subaward Monitoring If questions/concerns, discuss with sub and OSP as needed Speak with OSP Post-Award contact if unsure of whether charges are allowable Return to subrecipient for more detail or backup documentation Encourage subs to ask about allowability before incurring costs

Subaward Monitoring: Case Study Please take 10 minutes to read the case and review the questions with your table

Department/PI: Subaward Modification PI/Department submits a completed Subaward Modification Request Form to OSP Provide supporting documentation (updated budget and SOW if needed) for the amendment OSP will issue the amendment and will provide copies of the fully executed document to the PI/Department PI/Department will submit Purchase Order Change Request reflecting the increase / decrease in the dollar amount in the amendment, and will change the due date on the PO if the Period of Performance has changed Subaward Modification Request Form: http://www.bc.edu/content/dam/files/research/osp/DepartmentalSubawardModificationRequestForm.pdf

Pre-Award Award Post-Award Closeout Closeout

OSP: Closeout Closeout form is received from Sub Work with Dept. to deob if needed Review sponsor closeout requirement completed 1. Patent/invention report 2. Property report 3. Signed Release and assignment

Department/PI: Closeout PI/Department plan for a timely closeout Check status with subrecipient 90 days before end Follow up on any late or missing reports or deliverables Obtain final invoice (marked FINAL) from subrecipient Send copy of final invoice to OSP rep

Resources Links: http://www.bc.edu/research/osp.html http://www.bc.edu/research/osp/policies.html http://www.bc.edu/research/osp/subcontract.html

Questions? Contact OSP