Sponsored Project Administration Fall 2012 CERTIFICATION PROGRAM Sponsored Project Lifecycle Introduction Overview Creating a Project Budget Compliance Policies Proposal Submission Post Management Conducting & Managing the Project Final Reporting: Technical & Financial Electives and Review

CERTIFICATION PROGRAM SUBCONTRACTS Sponsore d Project Lifecycle Introduction Overview Creating a Project Budget Compliance Policies Proposal Submission Post Management Conducting & Managing the Project Final Reporting: Technical & Financial Electives and Review

CERTIFICATION PROGRAM OSP Subcontract Process What is a Subcontract? Subcontract or Professional Services Contract? Proposal Stage Award Stage Subrecipient Monitoring Subcontract Invoice Procedures Close Out Requirements Principal Investigator/ Subcontract Administrator Responsibilities

CERTIFICATION PROGRAM WHAT IS A SUBCONTRACT? 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.

CERTIFICATION PROGRAM SUBCONTRACT OR PROFESSIONAL SERVICES CONTRACT?

CERTIFICATION PROGRAM PROPOSAL STAGE  Legal Name of Subrecipient  Contact Name and Address  Tax ID# for Subrecipient  Subrecipient’s Scope of Work  Subrecipient’s itemized budget and budget justification  Subrecipient’s qualifications to do the work  Letter of commitment signed by Subrecipient institutional representative; may be in the form of a signed sponsor cover sheet  Sponsor certifications, if applicable

CERTIFICATION PROGRAM AWARD STAGE  The OSP Contract Administrator (CA) will process the prime award then send it to Contracts & Grants Accounting (CGA) for account set-up  CA notifies the Subcontract Administrator (SA) of the Subcontract  SA requests additional required documentation from Subrecipient or AU Principal Investigator (PI)  Subcontract draft is sent for PI approval  Following PI approval, Subcontract is sent to Subrecipient

CERTIFICATION PROGRAM ASSIGNING SUBCONTRACT NUMBERS The Subagreement number is assigned by OSP: (FY) - (College/Dept Acronym) - (Fund #) - (Subrecipient Acronym) For example: Fiscal Year 15 College Engineering Fund # Subrecipent Alabama A&M University The subcontract number would be: 15-ENG AAMU

CERTIFICATION PROGRAM SUBCONTRACTS Subagreement templates can be found at this link:

CERTIFICATION PROGRAM SUBRECIPIENT MONITORING OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR §200) (“Uniform Guidance”), specifically sections § and § , requires prime recipients of federal funds to monitor subawards and to ensure subrecipients meet the audit requirements in Subpart F and use funds in accordance with applicable laws, regulations and terms of the award.

CERTIFICATION PROGRAM SUBRECIPIENT MONITORING  System for Award Management (SAM)  Visual Compliance  Advise Subrecipients of all applicable federal requirements by including the appropriate flow-down provisions from the prime agreement  Federal Funding Accountability and Transparency Act (FFATA)  Routine Review of Technical Performance Reports  Compare Subrecipient Expenses to Budget  Conduct On-site visits and/or maintain regular contact  Perform Audits, if necessary  Verify that every subrecipient is audited as required by Subpart F— Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § Audit requirements  Review of Corrective Action Plans if findings are relevant

CERTIFICATION PROGRAM SAM SYSTEM FOR AWARD MANAGEMENT  Contractor Registration (CCR)/Federal Agency Registration (FedReg)  Online Representations and Certifications Application (ORCA)  Excluded Parties List System (EPLS)

CERTIFICATION PROGRAM FFATA FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT  FFATA provides public information on Federal award spending via one searchable website (USAspending.gov)  Federal Government uploads prime award information for Federal Awards  Prime Recipient uploads required elements into FFATA Subaward Reporting System (FSRS)

CERTIFICATION PROGRAM FACILITIES & ADMINISTRATIVE (F&A) COST RATE AGREEMENT A current F&A Cost Rate Agreement will be requested from Subrecipient. The Rate Agreement is imported into Xtender. A new F&A Cost Rate Agreement will be requested upon expiration of agreement on file.

CERTIFICATION PROGRAM FULL EXECUTION OF SUBCONTRACT  SA receives signed Subcontract from Subrecipient and obtains AU institutional signature  SA sends request to Payment and Procurement Services (PPS) to create Encumbrance. PI and Department Contact are copied on the request and will be notified with the Encumbrance number.  Fully executed Subcontract is mailed to Subrecipient, AU PI and CGA

CERTIFICATION PROGRAM CREATE ENCUMBRANCE At the time the Subcontract is fully executed, OSP encumbers the subcontract funds from the C&G Acct assigned FOP. The first $25,000 of each subcontract is encumbered in the account and the remaining balance is encumbered in the account (70790 and respectively for foreign subrecipients. Once an encumbrance number is set up, the PI and Dept Contact are notified by with the PPS assigned encumbrance number. The encumbrance number is referenced on all invoices submitted for payment under that subcontract. All modifications to the encumbrance are processed by OSP.

CERTIFICATION PROGRAM CREATE ENCUMBRANCE

CERTIFICATION PROGRAM SUBAGREEMENT MODIFICATIONS  OSP will obtain PI’s approval of requested changes and issue a Subcontract modification and/or modify the encumbrance accordingly  The modification will only address the specific terms of the original Subcontract to be modified. All other terms and conditions of the Subcontract will remain in effect and unchanged

CERTIFICATION PROGRAM DEPARTMENT INVOICING PROCEDURES Invoices require PI approval before being sent to OSP for processing PI ensures that the Subrecipient:  Meets the expectations outlined in the Subcontract’s Scope of Work and Budget  Submits required Technical Reports  Submits sufficient cost-sharing statements (if applicable)  Submits Final Close Out Documents

CERTIFICATION PROGRAM SUBAGREEMENT MODIFICATIONS

CERTIFICATION PROGRAM SUBAGREEMENT MODIFICATIONS

CERTIFICATION PROGRAM OSP INVOICING PROCEDURES  Verify Invoice Period of Performance dates are within Subcontract Period of Performance  Compare balance reflected in Subcontract Database and balance of Encumbrance (Banner Screen FGIENCD)  Confirm correct Vendor number, FOAP, and invoice amounts listed on Vendor Voucher  The invoice information is logged into the Subcontract Database  Invoice is scanned into Xtender  The invoice is sent to PPS for payment

CERTIFICATION PROGRAM CLOSE OUT REQUIREMENTS  Final Progress Report – This report is sent to PI from Subrecipient  Close Out Document – PI should review Close Out Document to ensure correct information regarding Final Progress Report date of receipt, equipment, patents, etc.  Final Invoice – This invoice will not be processed until OSP receives the Close Out Document

CERTIFICATION PROGRAM PRINCIPAL INVESTIGATOR  Subcontract Contact Form  Subrecipient Scope of Work  Subrecipient Itemized Budget and Budget Justification  Subrecipient qualifications to perform  Subrecipient Letter of Intent  Written approval for Subcontract Draft  Ensures Subrecipient meets expectations outlined in Scope of Work & Budget  Maintains Technical Reports  Approves Invoices and submits to OSP for approval  Submits sufficient Cost-Sharing statements  Reviews Close-Out Document and submits to OSP

CERTIFICATION PROGRAM SUBCONTRACT ADMINISTRATOR  Requests additional required documentation from Subrecipient or AU Principal Investigator (PI)  Subrecipient Monitoring  Drafts Subcontract  Submits Subcontract to PI for approval  Submits Subcontract to Subrecipient for institutional signature  Obtains AU institutional signature to fully execute the subcontract  Requests Encumbrance  Reconciles the balance of Encumbrance during the duration of the subcontract  Submits fully executed subcontract to Subrecipient, AU PI, and C&G Accounting  Approves Invoices to send to PPS for payment

CERTIFICATION PROGRAM QUESTIONS