Office of Sponsored Programs All rights reserved GTRC The New OSP Request for Subaward & Subrecipient Monitoring Course Dana Simpson: Contracting Officer, Sub-agreements Team Rob Roy: Director of Board of Regents Sponsored Programs Garrett Steed: Training Program Manager

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Overview Definitions and policies –Georgia Tech’s policies –Subrecipient –Request for Subaward –Vendor –Roles –Responsibilities –Risk –Authorization

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Georgia Tech’s Responsibility Georgia Tech is responsible for ensuring that all subrecipients of its sponsored research awards are in compliance with applicable requirements.

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Georgia Tech’s Guidelines

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Who is a Subrecipient OMB A-133 OMB A-133: A Subrecipient is a legal entity to which a sub award is made and which is accountable to the recipient for the use of funds provided. Financial assistance, or procurement, or contract made by a recipient to an eligible Subrecipient

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Subrecipients vs. Vendors OMB A-133 B.210 Federal award. Characteristics indicative of a Federal award received by a subrecipient are when the organization: (2) Has its performance measured against whether the objectives of the Federal program are met; Payment for goods and services. Characteristics indicative of a payment for goods and services received by a vendor are when the organization: (1)Provides the goods and services within normal business operations; (2) Provides similar goods or services to many different purchasers; Design and Develop (Sub) vs. Configure (Vendor)

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Subrecipients vs. Vendors Vendors are Not Subrecipients: and therefore do not include the purchase of goods and services Entities with in the USG can be an exception to this rule Design and Develop (Sub) vs. Configure (Vendor)

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Identifying eligible Subrecipient entities That are willing and able to comply with the requirements of the award Have accounting systems that are adequate to administer the award Have not been suspended or debarred from receiving federal funds

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Preparing a Statement of Work: SOW The Statement of Work is a document that: –lists and describes all essential and technical requirements for the effort to be performed –including standards to be used to determine whether the requirements have been met. Set your expectation and reporting requirements early, put them in the sub- award

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring SOW should include: Objective or Purpose Period of Performance Milestones A list of detailed work requirements Workload requirements Personnel requirements Resources (if any) to be furnished to the subcontractor

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Process Flow Identify need for Subaward Formal Request Submit Formal Request Review Request Prepare & Send Proposal Review Proposal Accept & Incorporate Into Proposal Submit Proposal App. Enter Subaward Request Into WebWise System Review and Affirm Compliance Approve Review Terms Communicate with PI & support staff to address issues Accept or Negotiate Terms Addressed? Find New Subaward PD/PI OSP Sub Pre-award Post Award Subaward Executed No Yes No

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Beginning a Sub Agreement Process To initiate: you will need to log into WebWise, using your GT account ID and Kerberos password. Under the OSP Contract Information System tab you will find a section for Subagreement Management.

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Step 1 To complete an on-line "Request for a Sub- Agreement" you will need to have –a detailed budget –statement of work (including deliverables & reports) –a short narrative as to why you selected the subcontractor –as well as a cost/price analysis

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Step 2 Enter your budget

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Step 3 Upload: a short narrative as to why you selected the subcontractor as well as a cost/price analysis

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Step 4 Upon final submission in the on-line system an will be sent to the Subagreements Team Notifications on progress will be sent via the ICOL system.

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Old Process Flow PD/PI A/P Sub PI reviews Enter into PeopleSoft Approve Yes Back to Sub for more detail Check Issued No Generates Invoice Dept. Admin receives invoice Process Complete Payment Received “Firsthand Knowledge”

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring New Process Flow PD/PI A/P Sub PI reviews Enter into PeopleSoft Approve Yes Back to Sub for more detail Check Issued No “Firsthand Knowledge” Generates Invoice Dept. Admin receives invoice Process Complete Payment Received OSP Receive Invoice Code Invoice & post on ImageNow Coding and scanning includes adding meta tags such as; PI, Fund #, and Amount Update on ImageNow Add Meta Data on ImageNow

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring A framework for compliance and expectation Reports = Document program progress Invoices = Request supporting material Budgets = Evaluate progress Tracking = Oversight (IRB reviews) Supervise = Understand where and why Authorization = Collect documentation

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Reports and Invoices Reviewing subrecipient reports and billings, and following-up on areas of concern –Does the billing/invoices amount accurately represent the amount of scientific data or progress by the sub? –Is there sufficient supporting documentation to determine if the expense on the invoice are allowable? (Think 3 years down the road)

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Budget Monitoring subrecipient budgets –Is the sub spending the money too quickly? Will they run out before the work is complete? –Is the sub having trouble getting started on the project?

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Tracking Tracking to ensure timely submission of required reports –WebWise:

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Authorization documentations: Know ahead of time what type of communication and how to authorization occurs –Signature Authority: who has it? –PI approval documentation Document…

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Short Break

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Verification Roles, Responsibilities & Risk Office of Sponsored Programs (OSP): Office of Sponsored Programs (OSP): ensuring that the Institute’s subrecipient monitoring procedures are compliant with regulations. Unit Financial Officers (Departmental Administrators): Unit Financial Officers (Departmental Administrators): assist PI’s in carrying out their responsibilities. Principal Investigators (PI): Principal Investigators (PI): is ultimately responsible Documentation Regulations

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Roles, Responsibilities & Risk Office of Sponsored Programs (OSP): ensuring that the Institute’s subrecipient monitoring procedures are compliant with federal and other applicable regulations this include: Compliance requirements Flow-down provision: Prime to sub Debarred or suspended check Audit certification letters from subrecipients

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Roles, Responsibilities & Risk Unit Financial Officers (Departmental Administrators): assist PI’s in carrying out their subrecipient monitoring responsibilities includes: Reviewing Invoice Approve & to A/P Excessive charges request clarification Maintain Invoices Maintain documentation of monitoring efforts Verify or confirm cost share (if required) has been met by Sub

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Roles, Responsibilities & Risk Principal Investigators (PI): management of federally funded projects includes: Monitor Review Verifying Approving Allowable, Allocable, Reasonable, & Period of Performance Keep records of notes of phone conversations and correspondence

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Roles, Responsibilities & Risk 4 Subrecipients Classes 1.Not-for-Profit: Large awards >$500,000 2.Not-for-Profit: Mid-sized awards $100,000 – $500,000 3.For-Profit Entities 4.Non US-based entities

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Risk Factors Size of the sub-award ($50,000 vs. $5,000,000) Percentage of pass-through Complexity of sub-award Sub-recipient’s experience –Administering –Deliverables Prior monitoring and audit results Single year vs. multiyear sub-award Type of entity –OMB-A-133 or not –Non-profit/Profit –Domestic/Foreign

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Know your sub-awardee Sub-recipient monitoring begins at proposal development An understanding of the capabilities of your sub-awardee can, and should drive your budget development and monitoring plan Assess the awardee Assess the level of expertise (Institution/College/Department) –Review what can be monitored –Tailor the agreement

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Know your sub-awardee –Review the latest A133 audit –Assess the SOP for Documentation –IRB (document IRB oversight and that it remains current ) –IACUC –Effort reporting – overload payments –Committed Cost Share –F&A (not everyone uses MTDC) –Assess your risk Set your expectations and reporting requirements –Delineate your deliverables – put them in the sub-award contract (request supporting documentation for each invoice)

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Financial Reports Recommend quarterly financial reports with business official signature –Makes sure everybody is watching –Triggers and focuses review in manageable bites –Reconciles invoices / payments / receipt of payment (facilitates annual report) –Include progress on cost share –Remember to document a relationship between programmatic progress and financial expenditures

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Keeping Risk In Mind… What is your purpose of sub-recipient monitoring? –Compliance –Need for technical assistance –Follow-up What is the associated risk of noncompliance –Experience of your sub-recipient

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Risk Exercise

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Overview & Closing Initiation Planning & Submission Closing/ Transition Proposal Development & SOW Eligible Subrecipient or vendors Reviewing Invoice Approve Deliverables Final Report & Deliverables Proposal Routing Sheet Set up infrastructure for project and monitoring Maintain Scanned Invoices & documentation – sending to A/P Archive documentation for Audit Verify Institutional Requirements Submit Proposal Debarred & Suspension Check Maintain Scanned Invoices Compliance Requirements Audit Letters Closeout Procedures PD/PI Dept. OSP RISK Assessment & Mitigation All ExecutionMonitor Iterative: test & evaluation SOW Requirements Milestones Deploy

Office of Sponsored Programs All rights reserved GTRC Subrecipient Monitoring Thank you