Subawards Overview of Subawards-Federal Definition Demonstration of Subaward PO Process- Requisition to Receiving

Federal Definition of Subaward Subaward (§200.92 – Uniform Guidance): is an award provided by a pass-through entity (PTE) to a subrecipient to carry out part of a Federal award received by the pass-through entity may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract Subrecipient (§200.93 – Uniform Guidance): is the non-federal entity that receives a subaward from a pass-through entity to carry out part of a federal program may also receive federal awards directly from a federal agency

Subrecipient Vs Contractors Subrecipients Contractors Receives a subaward, PTE determines who is eligible to receive the federal assistance Receives procurement contracts to provide goods and services within normal business operations Performance is measured in relation to federal award’s objectives Provides similar goods and services to many purchasers Has responsibility for making programmatic decisions Normally operates in a competitive environment Adheres to federal requirements specified in the award Provides ancillary goods or services to the federal program Carries out a program for public purpose, as opposed to providing goods or services to the PTE Not subject to compliance requirements of the federal award

Responsibilities of the PTE Ensure the subaward has 13 federal award identifications (name, EIN, FAIN, Date, POP, amount, project description, CFDA number, etc.) Flow down federal requirements to the subrecipient Impose additional requirements to meet PTE’s own financial & performance reporting responsibilities Ensure subrecipient is using federally negotiated F&A rate or a De minimis or negotiated rate Flow down audit requirements, granting access to auditors to subaward records & appropriate closeout terms and conditions

Why change the sub-awarding process Reduce the number of subaward projects in Oracle, reducing recon@ University’s purchase requisition system capturing subrecipient information in the market place vendor database Department encumbers negotiated subaward amount via a purchase order against a PI’s research project Transparency in PO balance, assists in managing subawards better, along with other expenses charged on the same project Three way match for payments of subrecipient’s invoices, confirming OSP and department oversight

New Subaward PO Process Department creates a Requisition OSP creates Purchase Order (flips Requisition to PO) OSP enters invoice and sends to department for approval Department receipts invoice

Creating a Requisition - Department Required Information Creating a Requisition - Department UVA Marketplace Select Non-catalog item Enter Supplier Product Description “OSP Subcontract – Year 1 funding from 01/01/2019 -12/31/19. Project Title: Studying the Subcontract PO Process.” Catalog No. “OSP-SUB” Quantity Amount obligated to subrecipient (does not include UVA’s F&A) Unit Price “1” UOM “EA-Each” Save and Close Checkout Return Cart to Integrated System Select Requisition Line Enter PTAO (Master Project/Award) Expenditure Type Svcs, Subcontracts, Spon Prgm (first $25K) Svcs, Subcontracts, OSP no F&A Apply Submit https://sponsoredprograms.virginia.edu/subcontract-purchase-order-guidelines

Key elements when creating Requisitions: When entering a requisition on an old account, send email to ospsub@Virginia.edu requesting to lift transaction controls on: “Svcs, Subcontracts, Spon Prgm” and “Svcs, Subcontracts, OSP No F&A” Department follows the Request Supplier to be Invited to Register Payments will be issued to the selected ‘Vendor’ Payments will be sent to the selected ‘Payment Address’ Requisition amount should always equal the amount obligated to the Subrecipient (Subrecipient’s direct and indirect budget) Oracle will burden UVA’s F&A based on the expenditure type Always enter one line per budget year and if F&A on first $25,000 enter two distribution lines (one to burden F&A with expenditure type: “Svcs, Subcontracts, Spon Prgm” and the second line without F&A, expenditure type: “Svcs, Subcontracts, OSP No F&A” When entering two distribution lines, always use the first line for the $25,000 that burdens F&A Process and submit the SP-30 with the Requisition as soon as the award is created in Oracle. The sooner OSP receives your request, the sooner it will be processed.

Flipping Requisition to Purchase Order - OSP Required Information SP-30 with supporting documentation UOM always should always be “Each” Requisition Quantity should match Subrecipient’s awarded amount listed on SP-30 Price should always be 1 Non-catalogue order with item number: OSP-SUB

Flipping Requisition to Purchase Order - OSP Key things to remember OSP creates additional lines for previous years currently as projects in Oracle to keep history of subcontract in one place OSP is responsible for maintaining Subcontracts PO: Release unspent funds when carry forward is restricted and transfer them to an Inactive Installment Close PO lines from previous years Finally close POs at the end of the award

Flipping Requisition to Purchase Order - OSP KEY THINGS TO REMEMBER DEPARTMENT Use the ‘Purchase Order Change Request Form’ when needing to: Finally Close Add/Change/Delete Lines Select OSP’s Buyer from the list Submit SP-30 to ospnoa@Virginia.edu when adding, changing or deleting lines in a Subcontracts PO, and also requesting allocation of Carry forward approved by the Sponsor OSP Finally close Subcontract POs (only) after receiving from the Subrecipient: Final invoice properly marked FINAL and approved by PI for payment PI approves all technical performance/progress reports Adds new lines to Subcontracts POs for Incremental funding New year funding (using current year’s master project in the distribution line) Carryforward approval received from Sponsor (approved carryforward will be added to current year funding line in the PO)

PO Invoice Overview Invoices continue to be submitted to osp-subcontractorinvoice@virginia.edu Post Award performs compliance review Invoice Certification present and signed Agreement Number Invoice billing period within Period of Performance and not duplicated Invoice is in English, and US Dollars Invoice Amount does not exceed current approved budget Supporting Documentation when applicable (Cost Share, Expenditure report, etc.) Post Award enters invoice data in Oracle and attaches copy of invoice Ensuring invoice date, amounts, correct expenditure type application, entering a description on the invoice line in Oracle indicating the invoice billing period, etc. Post Award emails PI and Fiscal Contact a copy of invoice stating by receiving this invoice in the Marketplace the PI has approved the invoice. PI should review the invoice for the following: Ensure deliverables have been met Milestones Achieved Expenditure are appropriate, allowable and allocable for the Subaward Provide the Fiscal Contact with authorization to pay by either an email or signing the invoice Fiscal Contact is responsible for the following: Review invoice and approval information from PI Proceeds with receipting of invoice in Oracle Marketplace for payment Attaches PI approval to receipt against the correct distribution line on the PO and finalizes receiving transaction.

Updated Invoice Email to PI and Fiscal Contact It is the department’s responsibility to ensure that deliverables have been met, milestones achieved, and expenditures are appropriate. Per Federal Regulations, the PI is responsible for the programmatic and financial performance of the Sub-recipient; by agreeing to pay this invoice the PI is certifying he/she has direct knowledge of the work performed by the subawardee and approves the expenses claimed in the invoice as being reasonable for activities performed to date. After review and approval, via signature of invoice or email communication please authorize your fiscal contact to proceed with receipting of invoice for payment or issuing payment voucher. Note to Fiscal Administrator: As the authorized payee please ensure the email confirmation or signed invoice is attached to receipted invoice or payment voucher.

Payment Voucher Process Update OSP will no longer require the invoice stamp to be signed. When the invoice is emailed to the PI and Fiscal Contact the standard invoice email language will be updated to reflect by paying the invoice the PI has provided their approval. The PI will now have the option to authorize the Fiscal contact to pay invoices either by email or by signing the invoice. Please attach a copy of the PI approval to the payment voucher.

Entering Invoice Details - OSP REQUIRED INFORMATION PO# Invoice date Invoice received date Invoice Number Description (invoice/billing period) Invoice Amount Terms (determined by vendor registration-changed as needed according to contract terms, i.e. foreign wire) Supplier site(confirm address is accurate) Distribute invoiced amount to correct expenditure types (F&A or No F&A) Attaches copy of invoice to paper clip Match and validate

Receiving an Invoice - Department 1. Receiving process for sub-invoices is similar to receiving other purchases 2. Receiving quantity = Invoiced dollars 3. Remember the first $25K of a subaward is received against the Svcs, Subcontracts, Spon Prgm exp type, which generates UVa’s portion of F&A Reminder to attach PI approval 4. To see expenditure type detail when receiving begin by selecting the requisition

Select Details Select Additional Information

Expenditure types will be displayed here Referencing back to the main screen we now can confirm the first distribution line is for F&A and the second line is without F&A

PO Receipting- Prompt Pay Reminders Prompt pay is based on the vendor terms and date of receipt of invoice.  If you are late entering an invoice, and completing the receiving, and the terms have passed, it is a miss for prompt pay.  UVA is held by the State to have a prompt pay status of 95%.  Late entries also affect our discounts if not met in a timely manner.

Payments against PO UBI Reports

Resources For additional resources regarding purchase order guidelines and frequently asked questions please visit: https://sponsoredprograms.virginia.edu/user-guides https://sponsoredprograms.virginia.edu/subcontract-purchase- order-faqs

Contacts Pre Award: ospnoa@Virginia.edu, ospsub@Virginia.edu Alice Reuther (asg3r@Virginia.edu) Post Award: osp-subcontractorinvoice@virginia.edu Kelly Mays (kds7c@Virginia.edu) Mike Priddy (mjp5em@Virginia.edu) Patra Wanant (pw3r@virginia.edu)