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Streamlining (sub)Award Management. Office of Sponsored Programs May 21, 2011 ospoff@syr.edu 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

ospoff@syr.edu

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


The sponsored project lifecycle transparency accountability to avoid fraud waste abuse
The Sponsored Project LifecycleTransparency & Accountability to Avoid Fraud, Waste & Abuse


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


The sponsored project lifecycle transparency accountability to avoid fraud waste abuse1
The Sponsored Project LifecycleTransparency & Accountability to Avoid Fraud, Waste & Abuse


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


    Project work plan comprises
    Project Work Plan comprises…


    The sponsored project lifecycle transparency accountability to avoid fraud waste abuse2
    The Sponsored Project LifecycleTransparency & Accountability to Avoid Fraud, Waste & Abuse


    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


    Subaward process transparency accountability to avoid fraud waste abuse
    Subaward process Transparency & Accountability to Avoid Fraud, Waste & Abuse


    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…