Subcontracts: Facilitating Collaboration through Collaboration

1. Subcontracts: Facilitating Collaboration through Collaboration OSR Quarterly Network Monday, August 12th Tyra Darville-Layne Senior Grant & Contract Officer Jon Chu Grants Assistant

2. Subcontracts in Context • Colleges and universities continue to see an increase in collaborations and large-scale multidisciplinary projects that unite colleagues not only from within, but frequently across institutions and organizations. • A subcontract is the mechanism often used to facilitate these collaborations.

3. What is a Subcontract? • A binding legal agreement that sets forth the expectations of the parties with regard to the scope of work and budget • Subrecipient responsible for the programmatic decision-making relative to its portion of the sponsored project • Subrecipient must adhere to compliance requirements (IRB, IACUC, FCOI, allowable costs, audit, terms/conditions flowed down from the prime sponsor)

4. Subcontracts - OSR’s Priorities OSR maintains its subcontracting priorities: • Efficiency and Customer Service -Metrics, project management -Allocation of resources • Risk Management -Compliance -Signature authority

5. Where were we with subcontract processing? • Centralization of subcontracting function to increase ability to manage risk and address need for high level customer service • Subcontract workgroup formed in spring 2012 • Included members of OSR and research administration staff from both Evanston and Chicago campuses • Resulted in 9 recommendations, presented at Fall 2012 OSR-Evanston Quarterly Network • What have we done with those recommendations?

6. Recommendation # 1- Subcontract Templates Recommendation: Subcontract Templates • Utilize FDP templates • Use of BI-Publisher Update: Subcontract Templates • BI-Publisher updated to improve functionality • Updated FDP templates, including FCOI language for PHS

7. Recommendation # 2 – Subcontract Request Form Recommendation: Subcontract Request Form • Consolidate the OSR-6 and OSR-7 forms into a single reformatted document Update: Subcontract Request Form • Drafted OSR-SUB form • Use of ESPR to electronically route requests • Streamlined questions and routing

8. Recommendation # 3 – Workflow Changes Recommendation: Workflow Change • OSR to initiate OSR-SUB request Update: Workflow Change • Weighed pros and cons of OSR vs. department • Best practice for department to initiate • Collaboration between OSR and department

9. Recommendation # 4 – Use of PAS Notes Recommendation: Use of PAS Notes • PAS notes flag involvement of one or more subcontracts Update: Use of PAS Notes • PAS notes now include a flag when subcontracts are involved

10. Recommendation # 4 – Use of PAS Notes • Subcontract Reminder:  There is a new subcontract with Name of the Subcontract Organization(s) on this project.  Please note that a request must be generated in ESPR routed to the Office for Sponsored Research.   This request authorizes a subcontract to be created and also provides OSR with key information about the desired subcontractor and the terms.  This form can be found at https://www.espr.northwestern.edu/ .

11. Recommendation # 5 – Research Compliance Recommendation: Research Compliance • IRB and ACUC Approvals Update: Research Compliance • eIRB and eACUC projects in process • Goal to ultimately have systems interface with InfoEd & ESPR

12. Recommendation # 6 – Subrecipient Questionnaire Recommendation: Subrecipient Questionnaire • Development of questionnaire to perform risk analysis Update: Subrecipient Questionnaire • Questionnaire revised • Issued to select subrecipient entities • Risk assessment then completed to understand category of risk

13. Determination of Low Risk vs. High Risk Lower risk subcontracts include the following attributes: • Subrecipient entity type: U.S. University, other experienced non-profit, previous subcontract with NU • Prime award terms and conditions: FDP/RTC – yes • Prime award mechanism is grant • Transaction: simple time and money, planned funding within 10% (or revised budget and SOW)

14. Determination of Low Risk vs. High Risk High risks subcontracts may include the following attributes : • Subrecipient entity type: for-profit, foreign, other less experienced non-profit , no previous subcontract with NU • Prime award terms and conditions: FDP/RTC – no • Prime award mechanism is cooperative agreement or contract • Compliance: FCOI, faculty start up, human or animal research involved, export controls • Cost share involved

15. Low Risk vs. High Risk

16. Recommendation # 7 –OSR-1/Routing Form Recommendation: OSR-1/Routing Form • Expand form to identify subcontract work with humans and/or animals Update: OSR-1/Routing Form • New language approved and form expanded • New language presented at upcoming brown bag

17. Recommendation # 8 –Delegated Signature Authority Recommendation: Delegated Signature Authority • Provide institutional delegated signature authority Update: Delegated Signature Authority • Signature authority delegated • Limited based on risk evaluation

18. Signature Authority Alignment to Risk

19. Recommendation # 9 –Metrics Recommendation: Metrics • Use InfoEd agreements tab to track status Update: Metrics • Subcontracts can be tracked in InfoEd agreements tab • General timeline on subcontract turnaround time: 1-2 weeks for low risk, 3-4 weeks for high risk

20. Turnaround Time: Setting Expectations Turnaround time from subcontract request, to subcontract issuance, to subcontract signature contingent on: • Collaboration among the research administrators and OSR • Complexity and level of risk • Compliance and flow through of terms and conditions • Delegated signature authority alignment to risk level

21. Other Changes • Constituencies removed from Tyra’s workload to further optimize subcontract processing • Exception: Chicago Biomedical Consortium (CBC) activity • Addition of GA support • Institutional subcontract policy in process • Upcoming plans for increased delegated signature authority • Updates on Subrecipient Commitment Form coming soon

22. GA Support Jon Chu provides direct GA support for the subcontracting function: • Review subcontract request in ESPR • Preliminary review and analysis • Open agreements tab in Infoed

23. GA Support • Review subcontract request and materials • Review Cognos report GM045 • InfoEd award summary review • Prime award terms and conditions • Human or animal subject approval documentation

24. GA Support InfoEd Agreements Tab: • Agreements tab is opened in InfoEd within 24 hours of last signature in ESPR and email notice to OSR • Status updates are recorded in real time • These best practices ensure accurate portrayal of metrics generated via Cognos report GM055 • Provides latest update to PI and RA staff • Submissions  New  Agreements

25. Implementation Highlights FFATA reporting delegated to subcontract function GA support added to subcontract function Bi Publisher updates completed 1st Draft of NU policy for subcontracting on sponsored projects Subcontract function officially centralized at OSR-Ev ESPR GO LIVE! Subrecipient Monitoring Guidelines, questionnaire 1st revision Initial FCOI Subrecipient Commitment form finalized Subcontract Workgroup Recommendations presented Subcontract Policy stakeholder engagement begins AUG 2013 MAR 2012 APRIL 2012 AUG 2012 SEPT 2012 MAR 2013 APRIL2013 MAY 2013 JUNE 2013 JULY 2013 Subcontract Policy approval DEC 2013

26. What can you do to help? • Timely & accurate completion of request in ESPR • Pre-review GM045 to confirm sufficient funds allocated to subcontract budget lines [request re-budgeting as needed] • Review planned budget vs. requested budget [provide revised budget and SOW when greater than 10% deviation from planned amount] • Use Infoed agreements tab to check status

27. QUESTIONS? Resources • To generate subcontract request: https://www.espr.northwestern.edu/ • For subcontract transaction status: http://infoed.northwestern.edu • For other questions: OSR-Subcontract-Ev@northwestern.edu