1. DSP: Wendy BeaverGAO: Jodi KennedyFebruary 9, 2016 Jessica Boyle Angie Klein Erin Brothers Kathie Gonzales Britt Murdock Edie Pierce-Thomas Angi Roemerman 1

2.  Overview, References, Responsibilities and UG (Jessica Boyle)  Subrecipient, Contractor or Consultant (Erin Brothers)  Proposal Submission with Subawards (Kathie Gonzales)  Issuing a New Subaward (Britt Murdock)  Invoicing, Monitoring and Closeout (Angie Klein)  Subaward Amendments (Angi Roemerman)  eSignatures, Pitfalls and DSP Research Tracker (Wendy Beaver) 2

3.  Overview, References, Responsibilities and UG (Jessica Boyle)  Subrecipient, Contractor or Consultant (Erin Brothers)  Proposal Submission with Subawards (Kathie Gonzales)  Issuing a New Subaward (Britt Murdock)  Invoicing, Monitoring and Closeout (Angie Klein)  Subaward Amendments (Angi Roemerman)  eSignatures, Pitfalls and DSP Research Tracker (Wendy Beaver) 3

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5.  DSP Subaward Website: http://dsp.research.uiowa.edu/subawards-university-iowa o Roles & Subaward Responsibilities o Forms o UI Outgoing Uniform Guidance (UG) Subaward Quick Guide  DSP Staff Directory: http://dsp.research.uiowa.edu/dsp-staff-directory http://dsp.research.uiowa.edu/dsp-staff-directory 5

6. 6 Resource: http://dsp.research.uiowa.edu/outgoing-subaward-roles-and- responsibilities-principal-investigatordepartmenthttp://dsp.research.uiowa.edu/outgoing-subaward-roles-and- responsibilities-principal-investigatordepartment

7. 7 Resource: http://dsp.research.uiowa.edu/outgoing-subaward-roles-and- responsibilities-division-sponsored-programs-dsphttp://dsp.research.uiowa.edu/outgoing-subaward-roles-and- responsibilities-division-sponsored-programs-dsp

8.  2 CFR 200.23 Contractor means an entity that receives a contract as defined in 2 CFR 200.22.  2 CFR 200.22 Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award (e.g., a purchase order at the UI). The term does not include a legal instrument when the substance of the transaction meets the definition of a Federal award or subaward. 8

9.  2 CFR 200.74 Pass-through entity means a non- Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program. 2 CFR 200.74  2 CFR 200.92 Subaward means an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a Federal award received by the pass-through entity.  2 CFR 200.93 Subrecipient means a non-Federal entity that receives a subaward from a pass- through entity to carry out part of a Federal program. 9

10.  Overview, References, Responsibilities and UG (Jessica Boyle)  Subrecipient, Contractor or Consultant (Erin Brothers)  Proposal Submission with Subawards (Kathie Gonzales)  Issuing a New Subaward (Britt Murdock)  Invoicing, Monitoring and Closeout (Angie Klein)  Subaward Amendments (Angi Roemerman)  eSignatures, Pitfalls and DSP Research Tracker (Wendy Beaver) 10

11.  Additional resources:  DSP Subaward website http://dsp.research.uiowa.edu/subawards-university-iowa  FDP Checklist to Determine Subrecipient or Contractor Classification FDP Checklist to Determine Subrecipient or Contractor Classification Determining the appropriate relationship at proposal stage is critical to ensure appropriate accounting for costs and compliance requirements. Misclassification may result in delays in proposal submission, subaward processing, inaccurate calculation of costs (e.g., failure to include or exclude F&A costs), and require additional time to request approval for project changes. 11

12.  Pass-Through Entity (PTE): The PTE is responsible for deciding whether an arrangement is a subaward, contract, or consulting arrangement.  Subaward: Carrying out intellectually significant portion of the award; key personnel may be considered authors on publications; the work requires IRB or IACUC approval. Processed through DSP after award is received  Contract: Obtaining goods and services; procurement relationship; provides a routine service in a competitive environment; provides similar goods or services to many different purchasers. Purchase order issued by UI Purchasing. Submit a Purchase Requisition.  Consulting: Advisory services Professional Services Agreement (PSA) issued by UI Purchasing Note: UI personnel working on the project are not considered as consultants. See “What is the difference between a Subaward, a Consulting/Professional Services Agreement, and a Contractor/Fee for Service Purchase Order” for more information.What is the difference between a Subaward, a Consulting/Professional Services Agreement, and a Contractor/Fee for Service Purchase Order 12

13.  PI has initial responsibility to determine collaborator’s status  PI/Department are encouraged to consult with DSP in advance of proposal submission when unsure of determination  When collaborating with individuals or sole proprietors outside of the University, and the work does not match the definition of a subaward, a Professional Services Agreement (PSA) through UI Purchasing is the appropriate tool  Collaborating with another UI department: Refer to UI Purchasing Inter-departmental Requisition for process 13

14.  Overview, References, Responsibilities and UG (Jessica Boyle)  Subrecipient, Contractor or Consultant (Erin Brothers)  Proposal Submission with Subawards (Kathie Gonzales)  Issuing a New Subaward (Britt Murdock)  Invoicing, Monitoring and Closeout (Angie Klein)  Subaward Amendments (Angi Roemerman)  eSignatures, Pitfalls and DSP Research Tracker (Wendy Beaver) 14

15.  Include Subrecipient’s budget and other required information in the UI proposal (i.e., budget justification, Letter of Intent, etc.) ◦ Consult with potential Subrecipient sites prior to proposal submission to obtain accurate budget information for proposal.  Consider sponsor requirements: ◦ Forms ◦ Budget categories ◦ F&A ◦ Conflict of Interest in Research ◦ Fixed Price Subawards under the Uniform Guidance ◦ Other requirements in funding announcement Fixed Price subawards must be explicitly and clearly requested in the Proposal with proper justification. We don’t want costs disallowed by the Sponsor-be prudent & detailed in your justification & budget request. Additional Online Resources: ICON Budget Course (Course # WBUDGT) 15

16.  Subrecipient’s federally negotiated F&A rate must be used on subawards unless a lower rate for the project is published by the sponsor (e.g., NIH caps F&A for foreign subrecipients at 8%).  NSF-if a subrecipient does not have a U.S. federally negotiated F&A rate, the 10% de minimus rate must be used (no less as that is considered voluntary committed cost sharing which is not allowed). This new rule applies to foreign subrecipient sites as well.  If a federal program has a published F&A cap, that rate must be used by both UI and all of the subrecipients.  For all other federal programs, if sub-recipient has a federally negotiated rate it must be used. Please obtain a copy of the subrecipient’s F&A rate for DSP.  For subrecipients without a federally negotiated F&A rate, 10% MTDC F&A rate must be used on federal awards. 16 Resource: http://dsp.research.uiowa.edu/subawards-university-iowa See Item #3 under ‘Required Documentation’http://dsp.research.uiowa.edu/subawards-university-iowa

17.  If a Sponsor has a published F&A cap, that rate must be used by the UI and is the maximum rate that can be used by the sub-recipients.  For all Not for Profit Sponsors without a published F&A policy the UI requires the use of 15% on Total Direct Costs (TDC). We recommend that the sub-recipient use our rate in this instance as a maximum rate for F&A.  For other Non-Federal Sponsors (i.e. Industry Sponsors) the UI must use our full F&A rate based on the category of research as appropriate and all sub-recipients that have federally negotiated rates may use their rates as well. Please obtain a copy of the subrecipient’s F&A rate for DSP.  For subrecipients without a federally negotiated F&A rate, 10% MTDC F&A rate may be used.  Published Rate: Rate explicitly stated in the Program Announcement or available on the Sponsor’s website. Cannot be an email or phone call, the rate limitation must apply to all applicants. 17 Resource: http://dsp.research.uiowa.edu/facilities-administrative-fa-costs Please review the appropriate F&A rate based on the type of project and Sponsorhttp://dsp.research.uiowa.edu/facilities-administrative-fa-costs

18.  UI prefers to issue cost-reimbursement subawards  Fixed price subawards under the UG have specific requirements and limits  Generally UI follows the prime award type of agreement 18

19.  2 CFR 200.332, 200.201  Prior written approval from Federal awarding agency (Note: if Fixed Price Subaward was in original proposal NIH’s award notice constitutes approval, all other agencies must have specific approval at this time)  Cannot exceed $150,000 cumulatively (simplified acquisition threshold)  Fixed Price subaward amounts do not fall under the re-budgeting authority. Sponsor approval is required to move funding to or from this category.  Fixed price amount is negotiated using cost principles or other pricing information as a guide  Fixed price subawards are not allowed if there is mandatory cost sharing or match  At the end of the subaward, subrecipient must certify the project or activity was completed or the level of effort was expended 19

20.  Overview, References, Responsibilities and UG (Jessica Boyle)  Subrecipient, Contractor or Consultant (Erin Brothers)  Proposal Submission with Subawards (Kathie Gonzales)  Issuing a New Subaward (Britt Murdock)  Invoicing, Monitoring and Closeout (Angie Klein)  Subaward Amendments (Angi Roemerman)  eSignatures, Pitfalls and DSP Research Tracker (Wendy Beaver) 20

21.  If Subrecipient is other than U.S. university, send the Audit Certification and Financial Status Questionnaire to Subrecipient  PI negotiates scope of work and budget with Subrecipient  Statement of work conforms to requirements of Prime Award 21

22.  If Subrecipient is a new vendor to the UI, send Vendor Application Form to Subrecipient  If Vendor is in database, but new address is needed, e-mail Purchasing Vendor File Team (VFT) purchasing-vendor@uiowa.edu with Vendor name, new address, phone, and contact person.purchasing-vendor@uiowa.edu 22

23.  If there will be an Advance Payment to the Subawardee, review the Advance Payment instructions, requirements and UI established payment schedule.Advance Payment  Advance Payments Advance Payments ◦ PI Subawardee Monitoring Assurance ◦ Subawardee Request for Advance of Funds ◦ Requires DSP and GAO approval ◦ Once PO is created PI/department must complete “Advance Payment Request Form” to process first payment ◦ Initial payment is 20% of annual award + equipment; Quarterly payments thereafter 23

24.  http://www.uiowa.edu/ap-purchasing/preqs http://www.uiowa.edu/ap-purchasing/preqs  Preq Resources for Departments: http://www.uiowa.edu/ap-purchasing/tools- departments http://www.uiowa.edu/ap-purchasing/tools- departments 24

25.  Use Category Code 99990000 – specific for Subawards  List subaward period of performance dates  List direct and F&A cost figures for the subaward budget period  Attach the statement of work  Attach the detailed budget, including supporting documentation for fringe benefits if not federally negotiated  Include contact email to whom the subaward draft should be sent.  Attach the Subaward Reporting Requirements form (required for subawards and amendments under federal grants). This form is recommended for other subawards. PI should determine reporting periods.Subaward Reporting Requirements form  Attach Audit Certification and Financial Status Questionnaire (required for Subawardees other than U.S. accredited institutions of higher education)Audit Certification and Financial Status Questionnaire  Attach other documentation as required by prime award  If replacing an existing PO, list the previous PO number  If requesting advance payment, attach advance payment forms  Route the Preq through Workflow 25

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28. 28 Category Code: 99990000

29.  Overview, References, Responsibilities and UG (Jessica Boyle)  Subrecipient, Contractor or Consultant (Erin Brothers)  Proposal Submission with Subawards (Kathie Gonzales)  Issuing a New Subaward (Britt Murdock)  Invoicing, Monitoring and Closeout (Angie Klein)  Subaward Amendments (Angi Roemerman)  eSignatures, Pitfalls and DSP Research Tracker (Wendy Beaver) 29

30.  Subrecipient should submit invoices directly to GAO for payment ◦ B5 Jessup Hall, Iowa City, IA ◦ uigao-subawardeeinvoices@uiowa.edu uigao-subawardeeinvoices@uiowa.edu  Cost-reimbursement subawards – subrecipient invoices the UI no more often than monthly  Subawards that include an Advance Payment schedule – subrecipient invoices the UI quarterly; monthly/quarterly financial reports must also be submitted 30

31.  GAO reviews invoices and sends to Accounts Payable for payment ◦ Invoice adequately meets UI invoice requirements ◦ Invoice includes Certification statement and is signed ◦ Invoice period falls within the Subcontract budget period ◦ Reviews invoices for consistency with subaward budget  PI/Department receives notification from Accounts Payable that a Subaward invoice requires “Receipt” ◦ Review invoices for consistency with subaward budget ◦ Assess that invoice is reasonable in light of subrecipient progress ◦ Assure compliance with the terms of the prime award ◦ “Receipts” voucher and approves payment through the e-Pro system  PI/Department contacts AP and GAO immediately with questions or if payment of an invoice should be placed on hold 31

32.  PI, Department and GAO all have monitoring obligations  PI receives progress and invention reports  PI maintains documentation of review (email, annotation with “reviewed” and date)  PI maintains subrecipient reports and other documents for the required document retention period (for federal awards generally three years from the project end date)  PI monitors financial and programmatic progress of subrecipient, including verifying expenses are proper and in accordance with subaward budget and award terms and conditions  PI notifies DSP and GAO immediately with concerns involving subrecipient performance 32

33.  Annually GAO requests and reviews subrecipient audits and/or financial reports ◦ GAO may determine additional documentation or reporting requirements are needed ◦ GAO works with DSP if changes are needed 33

34.  Grant Accounting sends a copy of the final invoice to the PI and Department for approval before sending to Accounts Payable ◦ PI/Department confirms completion of work ◦ PI/Department reviews final expenses are consistent with subaward budget ◦ PI/Department assures all required progress and invention reports have been or will be received ◦ All reports will be retained by the PI and department  Fixed Price subawards only - GAO requests Certificate of Completion from subrecipient  If necessary, Department and GAO work with AP to close Subaward PO 34

35.  GAO is working with AP to add assurances to the voucher Receipt notification email ◦ May also add assurances to the Receipt process within e-Pro  As of July 1, 2015, GAO is sending final subrecipient invoices to the PI and Department Administrator for approval ◦ PI will always be included on the email ◦ Email will clearly state that by approving final payment, the PI is assuring completion of work and expenses and their retention of required reports  GAO will require Certificate of Completion for Fixed Price Subawards 35

36.  Overview, References, Responsibilities and UG (Jessica Boyle)  Subrecipient, Contractor or Consultant (Erin Brothers)  Proposal Submission with Subawards (Kathie Gonzales)  Issuing a New Subaward (Britt Murdock)  Invoicing, Monitoring and Closeout (Angie Klein)  Subaward Amendments (Angi Roemerman)  eSignatures, Pitfalls and DSP Research Tracker (Wendy Beaver) 36

37.  http://dsp.research.uiowa.edu/revising-existing-subaward http://dsp.research.uiowa.edu/revising-existing-subaward  BR (Budget Reference) for the prime award is indicated on the AAAN  If the BR has not changed from the previous subaward, submit a Subaward Amendment Request Form  If the BR has changed from the previous subaward, submit a new Preq 37

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39.  If the BR does not change ◦ The UI’s default is to add new funding to the previously authorized subaward amount (i.e., the UI automatically approves carryover of unexpended funds). ◦ If the PI/department does not want to authorize carryover, contact DSP before submitting the subaward amendment request form  If the BR changes ◦ The UI’s default is not to authorize carryover ◦ If carryover is requested, contact DSP  Sponsor approval  Confirmation of the amount of unexpended funds  PI’s approval 39

40. 40 http://dsp.research.uiowa.edu/files/dsp.research.uiowa.edu/files/Subaw ard%20Amendment%20Request%20Form%204-27-15%20final_0.pdf

41.  Overview, References, Responsibilities and UG (Jessica Boyle)  Subrecipient, Contractor or Consultant (Erin Brothers)  Proposal Submission with Subawards (Kathie Gonzales)  Issuing a New Subaward (Britt Murdock)  Invoicing, Monitoring and Closeout (Angie Klein)  Subaward Amendments (Angi Roemerman)  eSignatures, Pitfalls and DSP Research Tracker (Wendy Beaver) 41

42.  DSP is going electronic ◦ Using Adobe for e signatures now ◦ Moving to DocuSign in the near future 42

43.  Attachments or information are missing from the Preq  Budget does not match Preq dollar amount  Vendor name in Preq system does not match subrecipient name  Agreement is pending subrecipient signature (this shows in Workflow as waiting on DSP approval; see DSP Tracker for more detailed status information)  Subawards under prime contracts generally take longer to draft than subawards under prime grants  Business Associate Agreement (BAA) is required 43

44.  DSP Research Tracker DSP Research Tracker  Search for UI Investigator (Simple or Advanced Search)  Advanced Search on: ◦ DSP Item # (formerly DSP Sequence number) ◦ Req Id # ◦ Grant Program # 44

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46.  Click on “project”, then expand “Out Going Subawards” (click on “+”) to see status information  Status Categories ◦ Pending – Agreement Requested ◦ Pending – Draft Sent to Subawardee ◦ Pending – Partially Executed and Pending UI Action ◦ Funded/Approved 46

47.  AAAN  Funding award notice (grant or contract)  Proposal and Award status  DSP reviewer  Subaward status and agreements  Related Non-Monetary agreements (phasing in) 47

48.  Division of Sponsored Programs (DSP)  2 Gilmore Hall  Phone: 335-2123  Email: dsp-contracts@uiowa.edudsp-contracts@uiowa.edu  Grant Accounting Office (GAO)  B5 Jessup Hall  Phone: 335-3801 48