1. Outgoing Subawards DSP: Wendy Beaver GAO: Jodi Kennedy June 12, 2015
Kathie Gonzales Angie Klein
Britt Murdock
Edie Pierce-Thomas
Angi Roemerman

2. References DSP Subaward Website
university-iowa
Process Flow Chart
Roles & Responsibilities
Subaward Forms
UI Outgoing UG Subaward Quick Guide
DSP Staff Directory directory

3. References: UG Definitions
2 CFR 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
2 CFR 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 Subrecipient means a non-Federal entity that receives a subaward from a pass- through entity to carry out part of a Federal program.

4. References: UG Definitions
2 CFR Contractor means an entity that receives a contract as defined in 2 CFR
2 CFR 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.

5. Proposal Stage Subrecipient or Contractor
Pass-through entity is responsible for deciding whether an arrangement is a subaward, contract, or consulting arrangement.
Subaward: Carrying out intellectually significant portion of the federal award; Key personnel may be considered authors on publications; work requires IRB or IACUC approval.
Processed through DSP
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
Consulting: Advisory services
Professional Services Agreement issued by UI Purchasing

6. Subrecipient or Contractor
Additional resources:
DSP Subaward website
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.

7. Subrecipient or Contractor
PI has initial responsibility to determine collaborator’s status
PI/Department are encouraged to consult with DSP in advance of proposal submission
Collaborating with individuals or sole proprietors: Professional Services Agreement (PSA) through UI Purchasing
Collaborating with another UI department (this is not a subaward handled through DSP)

8. Proposal Submission
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.

9. F&A on Subawards
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%).
For subrecipients without a federally negotiated F&A rate, 10% MTDC F&A rate must be used on federal awards.
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.

10. Fixed Price Subaward Requirements
2 CFR ,
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)
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

11. Project is Funded: It’s time to Issue the Subaward
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

12. Issuing a New Subaward
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, Purchasing Vendor File Team (VFT) with Vendor name, new address, phone, and contact person.

13. Advance Payments
If there will be an Advance Payment to the Subawardee, review the Advance Payment instructions, requirements and UI established payment schedule.
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

14. Complete the Preq 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
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.
Attach Audit Certification and Financial Status Questionnaire (required for Subawardees other than U.S. accredited institutions of higher education)
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

15. Preq

16. Types of Subawards DSP drafts the subaward
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

17. Subaward Invoices & Payments
Subrecipient should submit invoices directly to GAO for payment
B5 Jessup Hall, Iowa City, Ia
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

18. Subaward Invoices & Payments
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

19. Subrecipient Monitoring
PI, Department and GAO all have monitoring obligations
PI receives progress and invention reports
PI maintains documentation of review ( , 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
PI notifies DSP and GAO immediately with concerns involving subrecipient performance

20. Subrecipient Monitoring
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

21. Subaward Closeout
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
PI/Department assures all required progress and invention reports have been or will be received
Fixed Price subawards only - GAO requests Certificate of Completion from subrecipient
If necessary, Department and GAO work with AP to close Subaward PO

22. Subaward Amendments
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

23. Carryover under Outgoing Subaward Amendments
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

24. Uniform Guidance (UG) Overview
Effective Dec. 26, 2014, 2 CFR 200 (replaces A-21, A-110, and A- 133)
Does the UG apply to my federal grant?
NIH and NSF: UG applies to award notices dated 12/26/2014 or later that provide funding
ONR: If the award notice provides incremental funding for an existing award and the initial award was issued prior to 12/26/2014, the UG does not apply. If the award notice provides funding and does not meet the above existing award criteria, the UG applies.
Other federal agencies: If an award notice was issued on or after 12/26/2014, the UG applies

25. UG Requirements
No commingling of federal and non-federal funds (i.e., only 1 MFK per Preq) under awards subject to the UG
Additional subrecipient risk assessment monitoring
UI financial questionnaires have been revised to reflect UG rather than A-133 requirements:
New audit threshold is $750,000 in federal financial assistance
Invoices must include new certification as required in 2 C.F.R (a)
Required documentation of UI PI’s receipt and review of Subrecipient progress and invention reports
Certificate of Completion required for Fixed Price Subawards

26. Revised process
GAO is working with AP to add assurances to the voucher Receipt notification
May also add assurances to the Receipt process within e-Pro
Starting July 1, all final subrecipient invoices will be sent to the PI and Department Administrator for approval
PI will always be included on the
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

27. Changes to UG Subaward Format
FDP Subaward Templates
DUNS number is referred to as “Unique entity identifier”
Central Contractor Registration (CCR) and Excluded Parties List System (EPLS) no longer exist as standalone systems; functionality is included in System for Award Management (SAM)
Attachment 4, Reporting Requirements
Attachment 6, UI specific terms – See screen shots for images of the new face page and where the G/P number, Preq & PO numbers appear on Attachment 6.

28. Changes to UG Subaward Format

29. Changes to UG Subaward Format

30. Changes to UG Subaward Amendment Format

31. Finding Subaward Documents and Status Information
DSP Research Tracker
Search by:
ReqID Number
PO Number
Subrecipient Name
UI PI Name
UI Grant/Program Number
UI Sequence Number
Click on “project”, then Expand Out Going Subawards (click on “+”) to see status information

32. Contact Us Division of Sponsored Programs (DSP) 2 Gilmore Hall
Phone:
Grant Accounting Office (GAO)
B5 Jessup Hall
Phone: