Outgoing Subawards Proposal Stage DSP: Erin Brothers May 10, 2017 Kathie Gonzales Britt Murdock Edie Pierce-Thomas

Table of Contents Overview and Responsibilities (Erin Brothers) Proposal Submission with Subawards (Kathie Gonzales) Issuing a New Subaward (Britt Murdock)

Table of Contents Overview and Responsibilities (Erin Brothers) Proposal Submission with Subawards (Kathie Gonzales) Issuing a New Subaward (Britt Murdock)

Subawards What’s the purpose of a subaward? Subawards are utilized when a portion of the work related to an externally funded project is to be performed by a third party.

Contractor, Consultant, or Subrecipient Definitions Uniform Guidance (UG): Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. (2 CFR Part 200) Contractor: An entity that receives a contract as defined in 2 CFR 200.22. (UG 2 CFR 200.23) Contract: Obtaining goods and services; procurement relationship; provides a routine service in a competitive environment; provides similar goods or services to many different purchasers. A legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award (e.g., a purchase order at the UI). The term does not include a legal instrument when the substance of the transaction meets the definition of a Federal award or subaward. (UG 2 CFR 200.22) Purchase order issued by UI Purchasing. Submit a Purchase Requisition. Consultant/Consulting: Advisory services. Note: UI personnel working on the project are not considered consultants. Professional Services Agreement (PSA) issued by UI Purchasing The Guidance was drawn from OMB Circulars A–21, A–87, A–110, and A–122 (which have been placed in past OMB guidances); Circulars A–89, A–102, and A–133; and the guidance in Circular A–50 on Single Audit Act follow-up.

Contractor, Consultant, or Subrecipient Definitions (cont) Pass-Through Entity (PTE): The PTE is responsible for deciding whether an arrangement is a subaward, contract, or consulting arrangement. A non-Federal entity that provides a subaward to a subrecipient to carry out part of a Federal program (UG, 2 CFR 200.74) Subaward: Carrying out intellectually significant portion of the award; key personnel may be considered authors on publications; the work requires IRB and/or IACUC approval. An award provided by a PTE to a subrecipient for the subrecipient to carry out part of a Federal award received by the PTE (UG, 2 CFR 200.92) Processed through DSP after award is received Subrecipient: A non-Federal entity that receives a subaward from a PTE to carry out part of a Federal Program. (UG, 2 CFR 200.93)

Subrecipient, Contractor or Consultant Proposal Stage PI has initial responsibility to determine collaborator’s status. PI/Department are encouraged to consult with DSP in advance of proposal submission when unsure of determination. Correct determination is critical: delays in proposal submission; subaward processing; inaccurate calculation of costs; additional time to request approval for project changes PI has initial responsibility to determine collaborator’s status based on definitions provided Correct determination is critical to ensure appropriate accounting for costs and compliance requirements are considered. Misclassification may result in delays in proposal submission, subaward processing, inaccurate calculation of costs (e.g., failure to include or exclude F&A costs), and require additional time to request approval for project changes

Subrecipient, Contractor or Consultant Proposal Stage Contractor: Treated as any other purchase via the Purchasing Dept (i.e., not a subaward). Full F&A recovery for UI. Consultant: When collaborating with individuals or sole proprietors outside of the University, and the work does not match the definition of a subaward, a Professional Services Agreement (PSA) through UI Purchasing is the appropriate tool. Full F&A recovery for UI. Subrecipient: UI F&A recovery on first $25,000 of total subaward.

PI and Department Roles & Responsibilities Select subrecipients based on technical expertise and potential ability to perform the scope of work successfully, within the infrastructure of the prime award. The PI is responsible for determining the budget and monitoring subaward performance and payment, including monitoring the budget and scope of work for compliance with UI and sponsor policies and the terms of the prime award. Jessica

PI and Department Roles & Responsibilities cont. Include the Subawardee's Budget, Justification, and other required information as indicated in the funding opportunity announcement. Financial Conflict of Interest Policy If the UI is applying to a Public Health Service agency and the Subawardee is not listed on the FDP clearinghouse (as indicated on the UI Routing Form), Form B will be required before submission of proposal.  The DSP Proposal Routing Form will have additional instructions.

DSP Roles & Responsibilities DSP will ensure the budget and supporting documentation for the subawardee is accurate and appropriate Ensuring that the Conflict of Interest information is complete, where applicable (PHS agencies), before submission Submission of proposal DSP develops and negotiates the general administrative terms for subawards. Jessica

Are They a Subrecipient, Contractor or Consultant Based on the definitions, the PI will determine the appropriate relationship at proposal stage. This is critical to ensure appropriate accounting for costs and compliance requirements are considered. Misclassification may result in delays in proposal submission, subaward processing, inaccurate calculation of costs (e.g., failure to include or exclude F&A costs), and require additional time to request approval for project changes.

DSP Subaward References  DSP Subaward Website: http://dsp.research.uiowa.edu/subawards-university-iowa Subawardee Budget Statement of Work Template What is the difference between a Subaward, a Consulting/Professional Services Agreement, and a Contractor/Fee for Service Purchase Order? DSP Staff Directory: http://dsp.research.uiowa.edu/dsp-staff-directory FDP Website: FDP Checklist to Determine Subrecipient or Contractor Classification Jessica

Table of Contents Proposal Submission with Subawards (Kathie Gonzales) Overview and Responsibilities (Erin Brothers) Proposal Submission with Subawards (Kathie Gonzales) Issuing a New Subaward (Britt Murdock)

Proposal Submission Include Subrecipient’s budget and other required information in the UI proposal (i.e., budget justification, Letter of Intent, etc.) Consult with potential Subrecipient sites prior to proposal submission to obtain accurate budget information for proposal. Consider sponsor requirements: Forms Budget categories F&A Conflict of Interest in Research Fixed Price Subawards under the Uniform Guidance Other requirements in funding announcement Fixed Price subawards must be explicitly and clearly requested in the Proposal with proper justification. We don’t want costs disallowed by the Sponsor-be prudent & detailed in your justification & budget request. Additional Online Resources: ICON Budget Course (Course # WBUDGT)

F&A on Subawards Federal Sponsors If sub-recipient has a federally negotiated rate it must be used. Please obtain a copy of the subrecipient’s F&A rate for DSP and include it on the routing form or subaward request. For subrecipients without a federally negotiated F&A rate, 10% MTDC F&A rate must be used on federal awards. If a federal program has a published F&A cap, that rate must be used by both UI and all of the subrecipients.  Exceptions: Subrecipient’s federally negotiated F&A rate must be used on subawards unless a lower rate for the project is published by the sponsor (e.g., NIH caps F&A for foreign subrecipients at 8%). NSF-if a subrecipient does not have a U.S. federally negotiated F&A rate, the 10% de minimus rate must be used (no less as that is considered voluntary committed cost sharing which is not allowed).  This new rule applies to foreign subrecipient sites as well. Resource: http://dsp.research.uiowa.edu/subawards-university-iowa See Item #3 under ‘Required Documentation’

F&A on Subawards Non-Profits & Other Non-Federal Sponsors If a Sponsor has a published F&A cap, that rate must be used by the UI and is the maximum rate that can be used by the sub-recipients.  For all Not for Profit Sponsors without a published F&A policy the UI requires the use of 15% on Total Direct Costs (TDC).  We recommend that the sub-recipient use our rate in this instance as a maximum rate for F&A. Published Rate: Rate explicitly stated in the Program Announcement or available on the Sponsor’s website.  Cannot be an email or phone call, the rate limitation must apply to all applicants. If a Sponsor has a published F&A cap, that rate must be used by the UI and is the maximum rate that can be used by the sub-recipients. For other Non-Federal Sponsors (i.e. Industry Sponsors) the UI must use our full F&A rate based on the category of research as appropriate and all sub-recipients that have federally negotiated rates may use their rates as well. Please obtain a copy of the subrecipient’s F&A rate for DSP.  For subrecipients without a federally negotiated F&A rate, 10% MTDC F&A rate may be used. Resource: http://dsp.research.uiowa.edu/facilities-administrative-fa-costs Please review the appropriate F&A rate based on the type of project and Sponsor

Types of Subawards UI prefers to issue cost-reimbursement subawards Fixed price subawards under the UG have specific requirements and limits Generally UI follows the prime award type of agreement

Fixed Price Subaward Requirements 2 CFR 200.332, 200.201 Prior written approval from Federal awarding agency (Note: if Fixed Price Subaward was in original proposal NIH’s award notice constitutes approval, all other agencies must have specific approval at this time) Cannot exceed $150,000 cumulatively (simplified acquisition threshold) Fixed Price subaward amounts do not fall under the re-budgeting authority. Sponsor approval is required to move funding to or from this category. Fixed price amount is negotiated using cost principles or other pricing information as a guide Fixed price subawards are not allowed if there is mandatory cost sharing or match At the end of the subaward, subrecipient must certify the project or activity was completed or the level of effort was expended

Project is Funded: It’s time to Issue the Subaward If Subrecipient is other than U.S. university, send the Audit Certification and Financial Status Questionnaire to Subrecipient PI negotiates scope of work and budget with Subrecipient Statement of work conforms to requirements of Prime Award

Table of Contents Issuing a New Subaward (Britt Murdock) Overview and Responsibilities (Erin Brothers) Proposal Submission with Subawards (Kathie Gonzales) Issuing a New Subaward (Britt Murdock)

Finding Subaward Documents and Status Information DSP Research Tracker Search for UI Investigator (Simple or Advanced Search) Advanced Search on: DSP Item # (formerly DSP Sequence number) Req Id # Grant Program #

DSP Research Tracker

DSP Research Tracker Subaward Status Click on “project”, then expand “Out Going Subawards” (click on “+”) to see status information  Can also search by Req ID/PO number in simple search tab for status information Status Categories Pending – Agreement Requested Pending – Draft Sent to Subawardee Pending – Partially Executed and Pending UI Action Awarded

DSP Research Tracker AAAN Funding award notice (grant or contract) Proposal and Award status DSP reviewer Subaward status and agreements Related Non-Monetary agreements (phasing in)

Contact Us Division of Sponsored Programs (DSP) 2 Gilmore Hall Phone: 335-2123 Email: dsp-contracts@uiowa.edu Grant Accounting Office (GAO) B5 Jessup Hall Phone: 335-3801