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Subcontracts Procedures and Federal Regulations Susan Tompkins George Walueff
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TOPICS Purchase Orders Consulting Agreements Subcontracts Budget impact Initiating Subcontracts Invoices
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Subcontracts Performs substantive programmatic work under a grant or contract Bears responsibility for programmatic decision making and measurable performance requirements Subcontractor must adhere to compliance requirements of the primary award
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Subcontracts Continued…… Requires prior written permission of the sponsor. If in the proposal, award provides permission. If need arises for subcontract after award is made, required prior approval from the sponsor. NOT AN EMPLOYEE OF UD
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Subcontracts If, using the above criteria, you determine the service required is a subcontract then: Complete the Provider Category Determination Worksheet – Reviewed by OVPR and Procurement Services
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Purchase Orders The procurement of goods or services from an organization which provides the goods and services to many different purchasers as part of its normal business operations within a competitive environment With federal funds, not subject to same requirements as subcontractor NOT AN EMPLOYEE OF UD
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Consultants NOT AN EMPLOYEE OF UD Proven professional or technical competence You do not control manner of performance or result of service Work for hire UD retains rights to end product
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Budget Implications Subcontracts – first $25,000 charged facilities and administration costs Purchase Orders and Consultants – facilities and administration costs charged on all dollars This information should not be used to determine provider category
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Subcontract Initiation by Dept. If proposal is funded: Provide to OVPR – Provider Category Determination Worksheet (formerly OMB questionnaire) – Contact information – Statement of Work – Budget – Budget justification Prepare Purchase Requisition – With the information above attached
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Subcontract Initiation by OVPR Upon receipt of paperwork, OVPR prepares subcontract letter with attachments and forwards to Subrecipient Initiates negotiations with Subrecipient Work should not begin until award is issued
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Subcontract Initiation by Procurement Procurement Services – Reviews Provider Category Determination Worksheet – Obtains additional approvals as required <$50,000 Account Administrator, OVPR $50,000 - $100,000 also Dean >$100,000 - $250,000 also Provost >$250,000 also President – Obtains W-9 for tax id if not provided – Issues purchase order for payment purposes Subrecipient does not get copy
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Invoices Received by OVPR Forwarded to Principal Investigator for approval Invoices should include: – Summary of expenses by category Dollar amount Date Subgrant # Each invoice must contain the required certification (see Attachment 1): PI approves invoice and returns to OVPR OVPR sends to Procurement Services for payment
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Subcontract Close-out Subrecipient required to submit – Final Technical Report (Interim reports may be required by the Principal Investigator, this will be specified in the Subcontract) – Final Invoice (including cumulative costs and Cost Share) – Equipment Report – Patent/Invention Report – Subrecipient Release Forms
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USEFUL INFORMATION: Office of the Vice Provost Office Website, FAQs http://www.ovpr.udel.edu/OVPR/do/index?pageId=43
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Questions?
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