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Streamlining (sub)Award Management. Office of Sponsored Programs May 21, 2011 [email protected] X2807. Today’s goals… Get us all on the same page…. Help us learn about you BBI’s organizational structure Folks’ roles/responsibilities How you operate at various stages of the lifecycle

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streamlining sub award management

Streamlining (sub)Award Management

Office of Sponsored Programs

May 21, 2011

[email protected]

X2807

today s goals get us all on the same page
Today’s goals… Get us all on the same page…
  • Help us learn about you
    • BBI’s organizational structure
    • Folks’ roles/responsibilities
    • How you operate at various stages of the lifecycle
  • Review Sponsored Project lifecycle & guiding principles
  • Strategize on how to more efficiently work together to
    • Facilitate achieving the award’s goals & objectives while adhering to sponsor’s requirements & SU policies / practices
guiding principles
Guiding principles
  • Spending Federal Dollars
    • Comes with strings attached
    • Want to avoid knots or the noose
      • Why??
    • Fed’s expectations: ??
  • At proposal submission – SU agrees to follow award’s terms and conditions including following SU policies/procedures, reporting requirements & the cost principles, which require that costs are:
      • Allowable – under terms of award and SU or entity policy
      • Allocable – can reasonably determine benefit received by award and cost proportional to benefit
      • Reasonable – prudent person test (necessary)
      • Consistently treated – either direct cost or indirect cost
about bbi
About BBI
  • BBI’s organizational structure
  • Folks roles/responsibilities
  • How you operate at various stages of the lifecycle including communications & information management
find funding opportunities
Find Funding Opportunities
  • How & Who?
  • Go / no go process
  • Who notifies OSP (MMcB) about plans & when ?
  • COS
  • IRIS
  • Grants.gov / fbo.gov
  • Distribute to BBI leadership

BBI’s activities

OSP

it s a go you re going to apply
It’s a go – you’re going to apply
  • Who’s responsible for what?
  • Needs
    • FOA information ASAP
      • URL
      • PI & team
      • Partners (non-SU)
        • Ltr of Com’tnt AOR
        • SOW
        • Budget required format
    • Time to review & authorize
      • 7 b-days: budget
      • 3 b-days: complete app
    • Service guidelines

BBI

OSP

you re applying
You’re Applying….
  • Internal Review
    • What is goal of project?
    • Who has expertise?
      • BBI?
      • Collaborators??
      • What is each group doing?
      • Cost? Parts and whole
    • Info Management
      • Version control
      • Naming conventions
  • Reviews
    • Application adherence
    • IRR congruence
    • Confirmation of 3rd party approvals
    • FAR exceptions
    • Lots of other stuff…
  • Submits

BBI

OSP

subrecipient vendor consultant
Subrecipient / Vendor / Consultant

Decision to be made at proposal stage.

    • Not all treated the same in terms of F&A
    • Regardless of Type of 3rd party relationship –
      • In advance, have a SOW or at a minimum a clear understanding of what they will do for you
    • Characteristics of subrecipients, Vendors (purchased services) or consultants
      • Lots of detailed information
  • Subrecipient
    • Responsible for work and award performance
    • Subject to certifications/assurances (Human Subjects)
      • If at SU – would be PI or other key personnel
subrecipient vendor consultant1
Subrecipient / Vendor / Consultant
  • Vendor
    • Services provided are core to their mission
    • Provide same services for many customers
    • Price published or same rate for similar customers
      • May be non-profit organization
      • Caveat – IHE’s procedures may impact agreement type
  • Consultant
    • Individual who provides advice or discrete service modest scale
      • A type of vendor in terms of award T&C (e.g., not subject to human subjects assurances but may be subject to confidentiality provisions.)
      • Is “work for hire”
    • Use ‘worksheet for non-SU employees”
reminder application
Reminder - Application…
  • Made up of many parts…
  • Much of our focus is on:
    • Project plan – narrative, description etc
      • Including Statement of Work (SOW)
    • Budget
    • Budget justification
sow vs budget two sides same coin
SOW vs Budget - two sides same coin -

SOW

SOW

Budget

Budget is financial expression of statement of work (SOW).

Work drives costs; each collaborator should define & “own” SOW

award negotiation set up
Award Negotiation & Set Up
  • OSP responsibilities / tasks
  • BBI’s responsibilities / tasks
  • Subrecipient process  under award management
negotiate award osp
Negotiate Award - OSP
  • Grants / Contracts–
    • Standard Terms & Conditions or Troublesome clauses (reviewed and identified at proposal submission)
    • Where FAR exceptions accepted?
    • Was there a modification to submitted budget or work plan?
      • Adjust key personnel effort
      • Modify scope of work
      • Allowable costs?
award set up osp
Award Set up - OSP
  • Compliance check
    • Human subjects congruence
    • COI all folks
    • Debarment/suspension
    • IRR
    • etc
common omissions delays
Common omissions  delays…
  • No Internal Routing and Review form
  • No current COI for key personnel
  • Human subjects protocols pending
    • Allocate $$ (easier if clear up front)
      • Human Subjects
      • Not Human Subjects
  • Allocation of award to multiple SU units not clear
after negotiation compliance reviews award set up osp
After negotiation & compliance reviews… Award Set up - OSP
  • OSP  OSA for Chartstring creation (new award)
    • OSP  BBI PI, budget manager & project manager
      • Award package: chartstring, T&C etc.
      • New – OSP will confirm with BBI that any 3rd party partners are the same as in proposal
        • OSP will request institutional profile & conduct risk assessment
what about forward funding
What about forward funding?
  • When GRANT agreement isn’t in hand – request as soon as known and practical
  • Contracts: only when we know start date and it’s not effective dated; high risk
  • Same compliance reviews as for awards
  • Not allowed
    • Subrecipient costs
    • Human subjects costs without congruence complete
the sponsored project lifecycle transparency accountability to avoid fraud waste abuse3
The Sponsored Project Lifecycle Transparency & Accountability to Avoid Fraud, Waste & Abuse
manage the award discussion
Manage the award - discussion
  • Responsibilities
    • PI
    • Day-to-day
    • Financial
    • Subrecipient
    • Consultants
  • Information management
  • Negotiate amendments
  • Obtain sponsor prior approvals
  • Facilitate (sub)award administration
  • Facilitate compliance with SU / sponsor’s policies, T&C

BBI

OSP

award mngt worth repeating
Award Mngt: Worth repeating…
  • Review all expected obligations upon receipt of award materials
    • ALL BBI personnel effort: review / revise upon receipt of every new award and anticipated award.
    • 3rd party collaborations – plan ahead
    • Standing orders – plan ahead
      • Avoid confirming invoice attached
  • Not named folks debarment / suspension (epls.gov)
  • Review award materials especially terms and conditions to know what you can & can’t do.
  • DoL & cooperative agreements much less flexibility
    • You can’t move named personal around at will.
    • CONSIDER – name only essential folks
subrecipient management osp
Subrecipient Management - OSP
  • From risk assessment, develop subaward
    • Cost reimbursable vs fixed price WHY
    • Reporting requirements
    • Financial supporting docs etc
  • Execute subagreement
  • Create PO in ePro
  • Set up in SADb
  • Send subagreement to BBI
  • Monitor ‘process’
manage the sub award bbi discussion
Manage the (Sub)award – BBIdiscussion
  • Managing your Award
  • Award Management Aid
common challenges and the consequences
Common challenges… and the consequences
  • Collaborators
    • Letters of commitment from authorized rep.
      • Partner may reject award
      • Certs & Assurances not obtained from subaward  delays
    • Budget / budget justification
      • Financial risk
    • Statement of work missing or
    • Ambiguous standards of performance
    • Not unique to project
        • Errors in management
        • “Braiding & Blending”  allocobility concerns
deep dive request to
Deep Dive: Request to
  • Issue New subaward
  • Modify Existing subaward
  • Proposed- Subaward materials Transmittal
other matters
Other matters

Questions frequently asked of OSP

  • Why am I not being paid???
    • There is no agreement in place
      • No agreement – no obligation by SU
    • No invoice has been received
      • No invoice – no way to pay
  • Invoice review guidance
and a year goes by
And a year goes by….
  • Continuation…
non competing continuations process varies by sponsor
Non-competing continuationsProcess varies by sponsor
  • Annual Progress report
  • Complete ‘continuing application’
  • HINT: Work with sub’s same time to obtain updated SOWs and budgets for next budget period (~90d out)
  • Carry over?
  • Signs as authorized official or AOR, as required.
  • Reviews /approves budgets
  • Requests carry over, as applicable

BBI

OSP

potential speed bumps
Potential speed bumps
  • OSP not informed of continuation process
  • Subaward continuation challenges
    • Not done in a timely manner
    • Ambiguous statement of work
    • SOW similar to other awards
    • Budget poorly justified with little linkage to SOW
    • Inadequate budget justification
  • Baton gets dropped along the way – Communications / info management challenges
    • Agreement execution
    • Invoice management
close out
Close-out
  • Formal process to ensure that all University obligations to sponsor have been met.
    • Programmatic
      • All required reports
      • Invention reports
    • Financial
      • Final Financial report
        • Review all documentation
      • Property Reports
    • Subaward – as above
when bad things happen to good people
When bad things happen to good people
  • Accepting federal $$ comes with MANY obligations, i.e there are strings attached.
  • Current administration –
    • Transparency and accountability to avoid Fraud, Waste, and Abuse
  • Braiding and blending is not consistent with the allocobility cost principle
  • You will be audited.
    • Following regulations, policies & SU procedures; timely actions; and complete documentation are best protections against questioned costs, embarrassment, loss of reputation etc.
last audit
Last audit
  • Late awards to SU
    • Impacts subawards
    • Effort Reporting
    • Cost transfers – too many, and not timely
  • Debarment & suspension
    • Must be done prior to hiring
    • Sub’s – we ask for certification, but they are responsible for conducting epls check
future audits ig work plans a 133
Future audits (IG work plans / A-133)
  • Effort – personnel compensation and supplemental pay (Extra Service)
    • Subawardee effort procedures
  • Travel – especially foreign travel
  • Recharge Centers
  • Subrecipient monitoring
  • Administrative costs
  • Eligible activities
summary
Summary
  • Accepting federal $$ brings with it the obligation to be responsible steward of those $$
  • Efficient and effective practices facilitate stewardship
  • Strategize / document what can we each do to support this goal…
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