8/24/2016

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The Subaward Process – Part OneA Research Administrator’s Guide

Anne Lesky, SPARCS Amy Herman, SPARCS

With Assistance fromAllison Nelson, C&G

Brad Priser, C&G

Learning Objectives

After attending this session, you will:

• Know what proposal documentation to collect from each Subrecipient

• Understand the new process for Subrecipients in PINS

• View information from the Subrecipient Table in RADAR

• Submit a PMR subaward request under the new requirements

• Appreciate the steps involved in the subrecipient risk assessment process required prior to issuing a subaward

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UG Summary of Subaward Changes

• Increased burden to support Subrecipient vs. Contractor decision (200.330)

• F&A changes - Federally negotiated indirect cost rate (unless there is a program cap) or 10% MTDC de minimis (200.331 & 200.414)

• Increased burden on subrecipient monitoring (200.331) and tracking of subrecipient’s financial and programmatic reports (200.328)

• Must document risk assessment for each subrecipient prior to issuance (200.331)

• Requires process for screening and managing COI for PI and their subrecipients (200.112)

Federal Funding

If source of funding is FEDERAL the subrecipient should have:

• A DUNS number (2 CFR 25)

• An active SAM registration

– Certain agencies implement through supplemental guidance

– NCSU uses SAM registration to confirm subrecipients representations, certifications, and assurances and to verify DUNS

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The Subaward Process

PROPOSAL PROCESSING

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Subrecipient and Contractor Determinations

• UG clarifies that it is the PTE’s responsibility to make subrecipient/contractor determinations on a case by case basis

• Characteristics and classification of subrecipients and contractors (previously called “vendors”) remain the same as in A-133

• Federal Agencies may require us to support our determinations

If you have a Contractor…

https://materialsmgmt.ofb.ncsu.edu/Contract‐Review‐Services/Contract‐Review‐Services.php

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Subrecipient Proposal Package

Signed Checklist determining Subrecipient or Contractor

Letter of Intent – signed by authorized signatory

Statement of Work

Itemized Budget

Budget Justification

Curriculum Vitae for each PI

Copy of the federally negotiated F&A rate agreement, if applicable

Proof of current compliance approvals

Biosketches, pending support & other information required by Sponsor

Indirect Cost Rate of Subrecipient

• Federally negotiated rate between the subrecipient and the federal government should be used; unless the program has a capped F&A rate

• If subrecipient does not have a federally negotiated rate,apply a de minimis rate of 10% of MTDC

• NC State University will not negotiate indirect cost rateswith subrecipients

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Fixed Amount Subawards200.45 & 200.201 & 200.332

• Need prior written approval from awarding agency

– Include written request with justification for fixed amount subaward in proposal

• Limited to Simplified Acquisition Threshold ($150,000)

• Watch for exceptions in agency supplements!

• Can not be used in programs with mandatory cost share

• At close out, Subrecipient must certify in writing that the project is completed and/or the full effort occurred

PINS

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Adding Subrecipients in PINS

A new question will be added to the second tab in PINS currently labeled “Sponsors/Subs/Deadlines”

Upload Subrecipient’s Proposal Documents

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COI updates in PINS

• COI Question updated in Approvals/Routing:

– “Do you have a significant financial interest in or other conflict of interest with the sponsor of this project OR any proposed subrecipient, subcontractor, vendor, or consultant?

• COI Representation and Certification language updated to include subrecipients, contractors, vendors, and consultants

– I have on file a current and up to date COI disclosure and have considered my relationship with this sponsor and all subrecipients, subcontractors, vendors, and consultants, if any, and find all such relationships either free of a conflict of interest or consistent with a previously disclosed, up to date, and active conflict of interest management plan.

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Approval Certifications

* https://research.ncsu.edu/sparcs/systems‐portal/pins/help‐certifcation/

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PINS Approval Representations and Certifications

• Updated for Subrecipient certifications

** When you click “APPROVE” on the routing screen in PINS, you certify to the following regarding subrecipients:

– I certify that the subrecipient(s) was(were) selected based upon their technical expertise and ability to successfully perform the statement of work. (PI)

– I certify that the subrecipient’s technical and cost proposals were reviewed and the activities proposed were found to be allowable and appropriate to meet the programmatic objectives of the project and that the costs proposed are allowable, reasonable, and necessary for the work to be done. (PI and CRO)

RADAR

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New Electronic Subrecipient Questionnaire

Once the proposal is imported in RADAR, if needed, an electronic questionnaire will be automatically sent to the subrecipient

RADAR: Subrecipient Table

• Search for subrecipients that NC State has previously worked with

• View risk assessment levels

• Request to add new subrecipients

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New Subrecipients not in PINS

If a new subrecipient is not captured in PINS at the proposal stage:

• In Radar Subrecipient Table, “request a new subrecipient”

• A questionnaire will be sent and must be returned

• Risk assessment will need to be performed

PMR

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How to Avoid a PMR Return

DO obtain prior approval from the Agency, if required

DO ensure funds are in the prime Subcontract line

DO upload required documents to PINS or PMR

Subrecipient Proposal Package

only upload docs in PMR if not in PINS

Signed Checklist determining Subrecipient or Contractor

Letter of Intent – signed by authorized signatory

Statement of Work

Itemized Budget

Budget Justification

Curriculum Vitae for each PI

Copy of the federally negotiated F&A rate agreement, if applicable

Proof of current compliance approvals

Biosketches, pending support & other information required by Sponsor

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Rushes

• Rush Requests for Subawards

– Must include a Justification explaining the reasoning behind the rush

– Pursuant to the PMR manual, the RUSH field should only be used for the following criteria

• impending "agency imposed" deadline to submit request

• risk of loss of funding

• risk of loss of award

• risk of audit finding

A subaward can not be issued until a Risk Assessment is performed on the subrecipient.

RISK ASSESSMENT

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The Risk Assessment Matrix

NC State University has an obligation to perform a subrecipient risk assessment prior to issuing ALL subawards regardless of the type of funding

Risk Assessment Check Points

Subrecipient Questionnaire

Indirect Cost Rate

Audit ReportNC Debarred Vendors List

Compliance

FDP FCOI Institutional Clearinghouse for NIH funding

RCR for NSF, NIH, USDA‐NIFA

Sam.gov

•Active registration

FAPIIS Report

•Performance

•Integrity

Visual Compliance

•Restricted party screening

•Key Personnel

•Entity

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Determining Risk• Risk will be assessed as either:

– Low (<=15): no anticipated measurable effect on achievement of project’s goals and objectives

– High (<=24): Risk could compromise project goals and objectives or compliance with prime sponsor’s terms and conditions

(>=25): Requires management decision to go forward• Subrecipient debarred or suspended, has a conflict of interest;

• Financial management and accounting systems are inadequate to account for award funds in accordance with federal requirements;

• NO DUNS registration;

• Subrecipient will not complete questionnaire

High Risk Subrecipients• High Risk Subrecipients

– Foreign entities

– For-profits with no annual audit

– Subrecipients with significant audit findings without a defined corrective action plan

• Monitoring requirements

– Increase frequency of financial and technical reporting

• On a case by case basis

• Request supporting detail with invoice

• Issue smaller increments of money

• Add stop work language for failure to comply

• Exercise right to perform audit, desk review, or perform site visit

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SUBAWARD PROCESSING

How to Find the Risk Level and Monitoring Responsibilities

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Next Steps

• Obtain PI feedback regarding subrecipient performance quarterly, prior to issuing modifications, and/or at close out to use as additional risk assessment factor and as part of subrecipient monitoring to document that we are tracking reports

• Subaward Training – Part Two, Subrecipient Monitoring

Who do I contact for help?

Anne Lesky, Compliance Accountant & QAAmy Herman, Assistant Director for Subawards