1. Subcontracts: Deciphering ESPR Tyra Darville-Layne, OSR Evanston Melanie Mkrdichian, RA

2. What is a Subcontract? §200.92 Subaward. 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. Source : http://www.ecfr.gov/cgi-bin/text-idx?node=2:1.1.2.2.1#se2.1.200_192 http://www.ecfr.gov/cgi-bin/text-idx?node=2:1.1.2.2.1#se2.1.200_192 Electronic Code of Federal Regulations – U.S. Government Publishing Office Essentially, a subaward is a type of third-party legal agreement between NU, the institution receiving the grant – or another cooperative agreement, i.e. an incoming subaward to NU, and another organization that will perform research or other substantive work Subawards provide a contractual mechanism through which the University passes on the terms and conditions of the prime award to the subrecipient. Source: NCURA - A Primer on Subawards Under Federal Assistance Awards

3. Important Synonyms For the purpose of this presentation, it should be known that the following terms are used interchangeably for subrecipient: - Subcontractor- Subawardee - Sub-site- Consortium - Collaborator- Subgrantee For the purpose of this presentation, it should be known that the following terms are used interchangeably for subaward: - Subcontract- subk - Sub-agreement

4. How to log into ESPR

6. ESPR SUBCONTRACT REQUEST: NEW SUBAWARD

11. Tracking Number: Internal ESPR Number Institution Number: InfoEd Proposal Number  Make sure ESPR reflects the InfoEd Proposal Number Request Created By: Who OSR will contact if they have any questions and the person who OSR will cc on correspondence with the subrecipient

12. Subaward Organization Name: Make sure Full Legal Name is listed  OSR reviews on SAM.gov to see if Subaward Organization has:SAM.gov An active profile No delinquent federal debt No exclusions Correct legal entity name is used in the subaward If Subaward Organization Name is abbreviated or missing its full title, OSR has to review to ensure the subaward is issued to the appropriate organization

13. * Subaward PI name: Make sure Subaward PI name matches the following: – Budget – Budget Justification – Statement of Work * If any of the listed items don’t match, backup documentation is necessary. Upload into OSR additional documents.

14. * Contact person: OSR equivalent contact at subrecipient institution – Normally listed on LOI – If other contact is listed, subcontract takes longer to set up * Contact person email: Work email address * Contact person phone number: Can only list 10 digit phone numbers. Please list international phone number in Additional info for OSR, if applicable.

15. * If subaward was not previously approved by sponsor, additional questions will appear * If OSR subcontract GO requests sponsor approval for subcontract, additional information will need to be loaded into ESPR (minimum listed below, include all sponsor requirements): – LOI – SOW, Budget, and Budget justification – Letter to the Sponsor

16. Anticipated Subaward project period: Earliest start date can be the start of the NU award – Preaward spending cannot include subcontracts Latest end date can be end of the award – The project period end date does not have to be the entire NU project period Anticipated Subaward budget period: budget for current year of award Earliest start date can be the start of the NU award No later than authorized NU budget end date - Any continuation past a year will require an amendment Subcontract can be set up for as little as a month - dependent on what PI requires – this should be rare and only used for subrecipients that need a high level of monitoring

17. Chartstring: Make sure chartstring listed is correct Chartstring listed in ESPR needs to match NU Financial Chartstring Amount of subcontract: Year 1 budget amount Make sure the approved budget loaded in ESPR, the InfoEd budget, and the dollar amount listed match If budget does not match, include updated sponsor approved budget

18. If special reporting requirements are desired – click YES Text box will appear to add special reporting requirements If language entered is unclear, OSR will contact ESPR requester to finalize language that will be added to the subaward contract

19. If specific deliverables required– click YES Just like special reporting, text box will appear to include special deliverables OSR will contact requester if there are any questions

20. Has the budget changed from proposed by more than 10%: YES PI can choose award less funding for the subcontract If the budget change exceeds the 10% threshold – Enter PI confirmation that it does not change SOW – If there is a change to SOW, upload the revised SOW

21. Sufficient funds allocated for new subcontract: NO Load subaward budget and/or budget justification – ESPR request only allows one file to be attached, combine budget and justification – Click “Edit list of budget revisions” * Note that budget revisions must be completed before the subaward is finalized

23. Choose appropriate account and list increase/decrease amount Can only choose account once in dropdown list Please make sure to increase/decrease F&A, if necessary

24. Can subawardee do automatic carry forward? Always check Notice of Grant Award to see if carry forward is allowed; if the Award says carry forward is allowed without prior approval from the sponsor, then you can mark it as “Yes” For Chicago subcontracts, always receive approval from PI for carry forward Any rebudgeting restrictions? If yes is checked, text box will appear to list specific restrictions

25. Subaward cost share amount: If known, add cost share amount here – OSR will include cost share amount in subcontract Can subawardee do automatic carry forward? – Always check Notice of Grant Award to see if carry forward is allowed; if the Award says carry forward is allowed without prior approval from the sponsor, then you can mark it as “YES” – For Chicago subcontracts, always receive approval from PI for carry forward Any re-budgeting restrictions? – If YES is checked, text box will appear to list specific restrictions

26. Budget Justification: Categorical description of costs to complete work. Budget justification should address each of the major cost categories (salaries, fringe benefits, equipment, travel, supplies, other direct costs and indirect costs). Budget justification uploaded should only be for subaward site Can be uploaded as word or pdf document Approved Budget: Make sure approved budget loaded in ESPR, the InfoEd budget, and the dollar amount listed match Statement of Work (SOW): the detailed description of the work to be performed Load SOW for subcontract site only Can be loaded as word document or PDF

27. Human Subject/Animal Subject involvement: Click YES or NO depending if subaward site will use human subject/animal subject to complete its work OSR subcontract GO requests IRB and/or ACUC approval when partially executed subcontract is received at OSR - Contract will not be fully executed until all appropriate approvals are received

28. PHS compliant FCOI policy: YES OSR reviews FDP clearinghouse to see if subawardee is included If not, OSR informs COI to review subaward site’s FCOI policy PHS compliant FCOI policy: NO ESPR asks for Subcontract PI’s name, DOB, email address NUCOI Office makes sure all Subcontract Investigators complete FCOI disclosures PHS compliant FCOI policy: N/A Used only when sponsor does not require a FCOI policy NUCOI Office link to list of sponsors that follow PHS FCOI policy: – http://www.northwestern.edu/coi/policy/coi_by_sponsor.pdf http://www.northwestern.edu/coi/policy/coi_by_sponsor.pdf

29. Additional info for OSR: Any additional information listed will be included in the subcontract agreement OSR will contact requester if there are any questions Upload additional info for OSR (examples) If applicable, please upload complete Subrecipient Commitment Form If applicable, please upload materials needed to request sponsor approval to add subcontract If applicable, please upload subrecipient’s IRB/ACUC approval letter

30. Save Details: Saves all items entered in ESPR Save & Submit for Routing: Saves ESPR request and routes for approval - Route is determined based on how Department requested approvals Cancel & Back to Menu: Returns you back to Main Page

31. ESPR SUBCONTRACT REQUEST: SUBCONTRACT AMENDMENT

33. Institution Number: InfoEd Proposal Number  Make sure ESPR reflects the InfoEd Proposal Number

34. Project Chartstring: Make sure chartstring listed is correct Chartstring listed in ESPR needs to match NU Financials Chartstring Subaward Organization Name: List Organization name exactly how it is listed on previous Subcontract Agreement If Subaward Organization’s Name has changed, this needs to be noted in Additional info for OSR with an explanation Subaward PI name: List Subaward PI exactly how they are listed on previous Subcontract Agreement If subaward PI has changed, mark YES on “Change subaward PI”

35. Modify Period of Performance: YES A subaward cannot be issued for a new budget period if the correlating budget period for NU has not been setup in InfoEd & NU Financials Budget Period start, for subaward amendment, must be the day immediately following the preceding subaward’s budget period end date – Example: If the preceding subaward had a budget period end date of 6/30/15, then the next subaward amendment would have a start date of 7/1/15 Budget period end date cannot go beyond NU’s current budget period end date A gap of time between the subaward’s budget period may necessitate a new subaward – Example: A subaward cannot be an amendment if the previous budget period ended 6/30/15 and the next budget period starts on 7/2/15

36. Modify Statement of work: YES Load new SOW for subrecipient If SOW changes aims of project, sponsor approval will be needed

37. Change subaward PI: YES Note date of change from old subaward PI to new Write new subaward PI’s name (FIRST LAST) Date of change & new subaward PI will be included in the subaward

38. Change Subcontract funding: YES Amount of change can be positive or negative – If negative, a detailed budget that incorporates the budget reduction must be uploaded and it must show the new cumulative total for that budget period Cumulative amount to date will include dollar change associated with the ESPR Amount of change must match total cost listed in the uploaded budget

39. Sufficient funds allocated for subcontract amendment: NO Load subaward budget and/or budget justification – ESPR request only allows one file to be attached, combine budget and justification – Click “Edit list of budget revisions” * Note that budget revisions must be completed before the subaward is finalized

41. Choose appropriate account and list increase/decrease amount Can only choose account once in dropdown list Please make sure to increase/decrease F&A, if applicable

42. Carry forward automatically allowed on original subaward: YES OSR will contact requester if there carry forward is unclear Carry forward automatically allowed in original subaward: NO ESPR requires approval from PI that carry forward on unobligated balance Period number listed is subcontract year (e.g. year 1 to year 2) Carry forward automatically allowed on Primary Award: YES

43. Carry forward not automatically allowed in original subaward & PI does not approve for entire unobligated balance List dollar amount PI does approve for balance carry forward List new budget period dates Carry forward automatically allowed on Primary Award: YES

44. Has carry forward for subaward been approved by sponsor: NO Has carry forward for subaward been approved by sponsor: YES List dollar amount that Sponsor approved for carry forward Carry forward automatically allowed on Primary Award: NO

45. Carry forward automatically allowed: N/A Should only be used if subcontract is ≤ 1 year Carry forward automatically allowed on Primary Award: N/A

46. Complete just like Subcontract: New Subaward Request Human Subject/Animal Subject involvement: Click YES or NO depending if subaward site will use human subject/animal subject to complete its work

47. Upload technical Progress Report received from Subrecipient and approved by PI Additional terms, conditions, and info for OSR: Any additional information listed will be included in the subcontract amendment Must upload the detailed budget to “Upload additional info for OSR (optional)” if the ESPR requests deals with funding changes

48. Save Details: Saves all items entered in ESPR Save & Submit for Routing: Saves ESPR request and routes for approval Route is determined based on how Department requested approvals Cancel & Back to Menu: Returns you back to Main Page

50. QUESTIONS