Subcontracts: Deciphering ESPRTaylor Carl, OSR

Melanie Mkrdichian, Department of Surgery

What is a Subcontract?§200.92 Subaward.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. It does not include payments to a contractor or payments to an individual that is a beneficiary of a Federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract.

Source: http://www.ecfr.gov/cgi-bin/text-idx?node=2:1.1.2.2.1#se2.1.200_192

Electronic Code of Federal Regulations – U.S. Government Publishing Office

Essentially, a subaward is a type of third-party legal agreement between NU, the institution receiving the grant – or another cooperative agreement, i.e. an incoming subaward to NU - and another organization that will perform research or other substantive work

Subawards provide a contractual mechanism through which the University passes on the terms and conditions of the prime award to the subrecipient.

Source: NCURA - A Primer on Subawards Under Federal Assistance Awards

Important Synonyms

For the purpose of this presentation, it should be known that the following terms are used interchangeably for subrecipient:

- Subcontractor - Subawardee- Sub-site - Consortium- Collaborator- Subgrantee

For the purpose of this presentation, it should be known that the following terms are used interchangeably for subaward:

- Subcontract - subk- Sub-agreement

How to log into ESPR

https://www.espr.northwestern.edu/

ESPR SUBCONTRACT REQUEST: NEW SUBAWARD

Tracking Number: Internal ESPR NumberInstitution Number: InfoEd Proposal Number• Make sure SP number matches the proposal subcontract requestRequest Created By: Who OSR will contact if they have any

questions and the person who OSR will cc on correspondence with the subrecipient

Chartstring: Make sure chartstring listed is correct• Chartstring listed in ESPR needs to match NU Financial Chartstring

Subaward Organization Name: Make sure Full Legal Name is listed• OSR reviews on SAM.gov to see if Subaward Organization has:

• An active profile• No delinquent federal debt• No exclusions• Correct legal entity name is used in the subaward

If Subaward Organization Name is abbreviated or missing its full title, OSR has to review to ensure which organization is appropriate to award

the subaward

Subaward PI name: Make sure Subaward PI name matches the following• Budget• Budget Justification• Statement of Work

If there are discrepancies with the Subaward PI’s name, OSR will need to follow-up with person who made the request and, most likely, corrections will need to be made

Contact person: Preferably, the person at the subrecipient institution who’s in their central office• If this person is unknown or the subrecipient doesn’t have a central office,

then it should be the person who you’ve been working with at the subrecipient institution

Contact person email: Work email addressContact person phone number: Can only list 10 digit phone numbers. Please list international phone number in Additional info for OSR, if applicable

Amount of subcontract: Make sure approved budget uploaded in ESPR, the subrecipient’s budget in InfoEd, and Amount of subcontract are an exact match

Subaward cost share amount: If known, add cost share amount here• OSR will include cost share amount in subcontract

Anticipated Subaward project period: • Earliest start date can be the start of the award

– Preaward spending cannot include subcontracts

• Latest end date can be end of the award– The project period end date does not have to be the entire NU project period

Anticipated Subaward budget period: budget for current year of award• Earliest start date can be the start of the award• No later than authorized budget end date of prime’s period

– Any continuation past a year will require an amendment

• Subcontract can be set up for as little as a month; dependent on what PI requires – this should be rare and

only used for subrecipients that need a high level of monitoring

If sponsor requires prior approval for subcontracts, additional questions will appear

If OSR will request sponsor approval for subcontract, additional information will need to be loaded into ESPR (Upload Other Sponsor Documents):• LOI• Letter to the Sponsor

Has the budget changed from proposed by more than 10%: Yes• Save Subcontract ESPR and complete a revised budget request ESPR

Allocated funds for subcontract: No• Load subaward budget and budget justification in Uploads section

– Click edit list of budget revisions*Note that budget revisions must be completed before the subaward is issued

Choose appropriate account and list increase/decrease amount• Can only choose account once in dropdown list• Please make sure to increase/decrease F&A, if necessary

Can subawardee do automatic carry forward? • Always check Notice of Grant Award to see if carry forward is

allowed; if the Award says carry forward is allowed without prior approval from the sponsor, then you can mark it as “Yes”

• For Chicago subcontracts, always receive approval from PI for carry forward

Any rebudgeting restrictions? • If yes is checked, text box will appear to list specific restrictions

If special reporting requirements are desired – click Yes• Text box will appear to add special reporting requirements• If language entered is confusing, OSR will contact ESPR requester to finalize

language that will be added to the subaward• Reporting requirements language may already be used in the subaward

boilerplate in which case we may not add any additional reporting requirements

• Additional reporting requirements are best utilized for subrecipients who need a large amount of monitoring

• It may be necessary to work with OSR and/or ASRSP to draft language for additional reporting requirements

If specific deliverables required– click Yes• Upload Deliverables, preferably in pdf• OSR will contact requester if there are any questions

Statement of Work (SOW): the detailed description of the work to be performed• Load SOW for subcontract site only• Preferably PDF should be loaded

Approved Budget: Make sure approved budget uploaded in ESPR, the subrecipient’s budget in InfoEd, and Amount of subcontract are an exact match

Budget Justification: Categorical description of costs to complete work. Budget justification should address each of the major cost categories (salaries, fringe benefits, equipment, travel, supplies, other direct costs and indirect costs).• Budget justification uploaded should only be for the subrecipient

listed in the ESPR• Preferably PDF should be loaded

Any additional Sponsor Documents that OSR may need because of sponsor’s requirements listed in the NoA, examples include:• Subrecipient’s IRB and/or ACUC approval• Work Plan• Letter to Sponsor

Human Subject/Animal involvement: Click yes or no depending if subaward site will have human subject/animal involvement

Subaward site will need ACUC or IRB approval sent to Northwestern prior to animal or human subject work to be completed

PHS compliant FCOI policy: No• ESPR asks for Subcontract PI’s name, DOB, email address• COI Office makes sure all Subcontract Investigators complete FCOI disclosures

PHS compliant FCOI policy: N/A• Used only when sponsor does not require a FCOI policy• NU’s COI Office link with sponsor’s who follow PHS FCOI policy:

– http://www.northwestern.edu/coi/policy/coi_by_sponsor.pdf

Additional info for OSR: text inserted here should be used if there are unique circumstances associated with the grant and/or subaward that would help streamline OSR’s issuance of the subaward• OSR will contact requester if there are any questions

Upload additional info for OSR• If possible, please upload complete Subrecipient Commitment Form

Save Details: Saves all items entered in ESPR

Save & Submit for Routing: Saves ESPR request and routes for approval• Route is determined based on how Department requested approvalsCancel & Back to Menu: Returns you back to Main Page

ESPR SUBCONTRACT REQUEST: SUBCONTRACT AMENDMENT

Make sure InfoEd number matches the proposal subcontract request

Project Chartstring: Make sure chartstring listed is correct• Chartstring listed in ESPR needs to match PAS

Subaward Organization Name: List Organization name exactly how it is listed on previous Subcontract Agreement• If Subaward Organization’s Name has changed, this needs to be

noted in Additional info for OSR with an explanation

Subaward PI name: List Subaward PI exactly how they are listed on previous Subcontract Agreement

Subaward cost share amount: If known, add cost share amount here• OSR will include cost share amount in subcontract

Modify Period of Performance: Yes• A subaward cannot be issued for a new budget period if the correlating budget period for

NU has not been setup in InfoEd & NUFS

• Make sure new budget period dates are in compliance with Notice of Grant Award

• Budget Period start, for subaward amendment, must be the day immediately following the preceding subaward’s budget period end date– Example: If the preceding subaward had a budget period end date of 6/30/15, then

the next subaward amendment would have a start date of 7/1/15

• A gap of time between the subaward’s budget period would necessitate a new subaward– Example: A subaward cannot be an amendment if the previous budget period

ended 6/30/15 and the next budget period starts on 7/2/15• Budget period end date cannot go beyond NU’s current budget period end date

Modify Statement of work: Yes• Load new SOW for subrecipient• If SOW changes aims of project, sponsor approval will be needed

Change subaward PI: Yes• Note date of change from old subaward PI to new• Write new subaward PI’s name (FIRST LAST)• Date of change & new subaward PI will be included in the

subaward

PHS compliant FCOI policy: No• ESPR asks for Subcontract PI’s name, DOB, email address• COI Office makes sure all Subcontract Investigators complete FCOI disclosures

PHS compliant FCOI policy: N/A• Used only when sponsor does not require a FCOI policy• NU’s COI Office link with sponsor’s who follow PHS FCOI policy:

– http://www.northwestern.edu/coi/policy/coi_by_sponsor.pdf

Upload Biosketch and Other Support

Change Subcontract funding: Yes• Amount of change can be positive or negative

– If negative, a detailed budget that incorporates the subtraction must be uploaded and it must show the new cumulative total for that budget period

• Cumulative amount to date will include dollar change associated with the ESPR

• Amount of change must match total cost listed in the uploaded detailed budget

Allocated funds for subcontract amendment: No• Load subaward budget and/or budget justification

– If both should be loaded, attach file request only allows one item to be attached

– Click edit list of budget revisions*Note that budget revisions must be completed before the subaward is issued

Choose appropriate account and list increase/decrease amount• Can only choose account once in dropdown list• Please make sure to increase/decrease F&A, if necessary

Carry forward automatically allowed on original subaward: YES• OSR will contact requester if there is carry forward confusion

Carry forward automatically allowed in original subaward: NO• ESPR requires approval from PI that carry forward on unobligated balance

Carry forward automatically allowed on Primary Award: YES

Carry forward not automatically allowed in original subaward & PI does not approve for entire unobligated balance• List dollar amount PI does approve for balance carry forward• Upload a detailed budget for the carryover dollar amount

included in the ESPR• List new budget period dates

Carry forward automatically allowed on Primary Award: YES

Answering these two questions with a “No” means the subaward will not allow any carry forward for the subrecipient

Has carry forward for subaward been approved by sponsor: YES• List dollar amount that Sponsor approved for carry forward• Upload a detailed budget for the carryover dollar amount included in the ESPR• Upload sponsor’s approval of the carryover

Carry forward automatically allowed on Primary Award: NO

Carry forward automatically allowed: N/A• Should only be used if subcontract is ≤ 1 year

Carry forward automatically allowed on Primary Award: N/A

Complete just like Subcontract: New Subaward Request

Upload technical Progress Report received from Subrecipient and approved by PI

Additional terms, conditions, and info for OSR: Any additional information listed will be included in the subcontract amendment• Must upload the detailed budget to “Upload additional info

for OSR (optional)” if the ESPR requests deals with funding changes

Save Details: Saves all items entered in ESPR

Save & Submit for Routing: Saves ESPR request and routes for approval• Route is determined based on how Department requested

approvals

Cancel & Back to Menu: Returns you back to Main Page

QUESTIONS