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Outgoing Subawards and Subrecipient Monitoring

Procedure: OSP – Outgoing Subawards & Monitoring

Effective: July 1, 2019

Owner: Office of Sponsored Programs

Latest Revision: June 25, 2019

Scope

The purpose of this procedure is to assist the Office of Sponsored Programs, principal investigators and departmental administrators in the preparation and administration of outgoing subawards issued under sponsored programs.

All Sponsored Awards received by the University that include collaborative sponsored research services from a third party (usually another academic institution) in support of the technical goals and outcomes of the award are required to have a subaward agreement formalizing the collaborative relationship between the University and the third party. All such subaward agreements are issued and negotiated by the Office of Sponsored Programs (OSP). This procedure does not cover subawards that the University of Virginia receives from other institutions (incoming subawards), nor does it cover procurement activities under Sponsored Awards for the purchase of goods and services.

Definitions

Sponsor – An external funding source that enters into an agreement with the University to support research, instruction, public service or other sponsored activities. Sponsors include for-profit organizations, foundations and other not-for-profit organizations, other universities, and federal, state and local governments.

Sponsored Award – The grant, contract or cooperative agreement document issued by the Sponsor and accepted by the University of Virginia that provides financial assistance and the terms and conditions under which the sponsored activity occurs.

Pass Through Entity (2 § 200.74) – A non-federal entity that issues a subaward to a Subrecipient to carryout part of a sponsored program.

Subaward (2 § 200.92) - “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.”

A subaward is issued by the University as the Pass Through Entity (PTE) to another institution or organization (Subrecipient) to perform an programmatically significant portion of the Statement of Work (SOW) in a collaborative effort with the University under a University sponsored project.

Subrecipient (2 § 200.93) - “Subrecipient means a non-Federal entity that receives a subaward from a pass-through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency.”

The Subrecipient has responsibility for programmatic decision making related to the SOW; is responsible for adherence to applicable Federal program requirements specified in the Federal award; and in accordance with its agreement (subaward), uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.

Scope of Work – The Scope of Work outline the procedures and methods, which will used by the Subrecipient to accomplish the goals of the subaward.

Facilities and Administrative Costs (F & A) – F & A costs (also known as “indirect costs”) are those that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other institutional activity. The University's F&A costs are consistent with the definitions of specific F&A cost categories in 2 CFR Appendix III to Part 200 - Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Institutions of Higher Education (IHEs)

Off-Grounds Rate - The University’s approved F&A rate for sponsored programs on which >50% of professional effort will be conducted in or on land, buildings or other space not owned by the University (state agency 207 or state agency 246) where all operation and maintenance expenses are directly incurred by the cost objective specifically benefited or are initially incurred by a Revenue Generating Activity (recharge center/service center) and then allocated to the cost objectives specifically benefitted based on an allocation plan approved by the Office of Cost Analysis. Off-Grounds locations may be privately rented/leased, government-owned, or owned by another university.

On-Grounds Rate - The University’s approved F&A rate for sponsored programs on which >50% of professional effort is conducted in or on land, buildings or other space owned by the University (state agency 207 or state agency 246) and land, buildings or other space leased by the University where the operation and maintenance expenses are incurred by non-sponsored University funding sources, e.g., state or local award types, and cannot be readily and specifically assigned to a particular project or cost objective. For the purposes of this policy, On-Grounds locations do not include leased land, buildings or other space where all operation and maintenance expenses are initially incurred by a Revenue Generating Activity (recharge center/ service center) and then allocated to the projects or cost objectives specifically benefitted based on an allocation plan approved by the Office of Cost Analysis.

The University of Virginia charges F&A on the first $25,000 of each subaward under any award which allows F&A, and for each competitive cycle of the award. If the prime award allows F&A to be calculated on "total direct costs (TDC)" then UVA's portion of the F&A on the subaward shall be on the entire funding amount of the subaward.

SP -30 (Subcontract/Subaward Request Form) – Form used when requesting a new subaward or a modification to an existing subaward under a sponsored award.

References

Policy

Responsibilities

Office of Sponsored Programs

OSP is responsible for the issuance, negotiation, acceptance and certain compliance monitoring aspects of all outgoing subawards and modifications. Financial monitoring includes financial reports, spending patterns against authorized budgets, invoice processing and overseeing special award conditions, such as cost sharing, reporting on program income, and other regulatory and statutory requirements. As the PTE, the University is responsible for reviewing Subrecipient’s performance reports, audit reports, site monitoring reviews and management actions related to timely resolution of audit findings.

School/Departmental Administrators

The Department is responsible for timely submission to OSP of documentation pertaining to Subaward issuance, modification, and closeout. The Department also is responsible for obtaining Principal Investigator approval and paying Subrecipients’ invoices.

The Principal Investigator

The Principal Investigator (PI) is responsible for requesting issuance of subawards and subsequent modifications under his or her Sponsored Awards. The PI is responsible for monitoring technical progress of the Subrecipient and reviewing and approving Subrecipient invoices for appropriateness.

Distribution

  • Office of Sponsored Programs Contract and Grant Administrators
  • Research Administrators
  • Fiscal Technicians
  • Principal Investigators

Ownership

The Executive Director of the Office of Sponsored Programs is responsible for ensuring that this procedure is necessary, reflects actual practice, and supports University policy.

Workflow Process

Proposal Phase

The Principal Investigator

  • The PI initiates the collaboration by completing the Subrecipient Determination Form.

  • The PI requests and receives a proposal with SOW, budget and budget justification from the Subrecipient to be incorporated in the PI’s proposal submitted to the Sponsor.

School/Departmental Administrators

The School/Departmental administrator assists the PI in compiling the following Subaward proposal packet:

  • Proposal Face Page or equivalent (e.g. Letter of Intent) endorsed by Subrecipient’s authorized official.
  • Subrecipient’s Consortium Form. This requirement is waved if Subrecipient is listed on the FDP Expanded Clearinghouse.
  • Clearly defined SOW to be performed by the Subrecipient’s personnel, using its own facilities and resources.
  • Detailed Budget relevant to the SOW & Budget Justification –including letter of commitment when cost sharing is required.
  • Biosketch for all Key Personnel.
  • Certification of compliance with Public Health Service (PHS) Conflict of Interest (COI) Regulations. If the Subrecipient does not have a compliant COI Policy, it will have to adhere to the University’s COI Policy and is required to submit the Key Personnel’s Annual Financial Disclosure Form.
  • Copy of Human Subjects Research Training and Good Clinical Practice certificate(s) (if applicable).

Office of Sponsored Programs, School of Medicine’s Office of Grants and Contracts, and School of Engineering and Applied Science’s Office of Grants and Contracts:

These offices submit proposals to the Sponsors on behalf of the University.

Award Phase

The Principal Investigator

  • To initiate the issuance of a subaward upon receipt of an award or an award modification, the PI reviews and signs an SP-30 authorizing the establishment of a new subaward or an amendment to an existing subaward.(See School/Departmental Administrators).

  • If at the Award Stage the PI identifies the need to collaborate with another institution or organization, the PI will contact OSP to determine if Sponsor approval is required and will seek Sponsor approval to engage on such collaboration. If the Sponsor is a member of the FDP, Sponsor approval may not be required.
  • The PI assesses the Subrecipient’s technical progress and required reports and approves Subrecipient invoices for payment. (See also “Subrecipient Invoices” section.)
  • The PI provides to OSP specific information included on the SP-30 regarding Subrecipient’s performance. If the subrecipient’s performance is unsatisfactory, the PI has an affirmative obligation to notify OSP of such performance by emailing ospsub@virginia.edu.

School/Departmental Administrators

The School or Department Administrator prepares an SP-30 FORM when a new subaward or a modification to an existing subaward is required. For a new subaward Sections A.1, B, C and D are completed. For a modification to an existing subcontract or subaward, Sections A.2, B, C and D are completed. It is necessary to complete all sections and provide required supporting documents as follows:

  • Subaward proposal Packet (updated budget, budget justification and SOW must be incorporated if final version differs from the original documents included in the proposal to the Sponsor)
  • Requisition number from the University’s financial system. See ‘Creating a Requisition for a Subaward’, and ‘Requesting a Change to a Subcontract Purchase Order’.
  • If applicable:
    • IRB approval (Institutional Review Board approval to perform Human Subject Research)
    • IACUC approval (Institutional Animal Care and Use Committee approval to perform research on vertebrate animals)
    • IBC approval (Institutional Biosafety Committee approval to perform research that involve the use of biological agents)
    • Export Controls Management Plan
  • Except for the Schools with delegated authority to their School Post Award Grants Administrator, the SP-30 must be signed by the PI and routed through the proper channels to OSP.

Office of Sponsored Programs

  • OSP will evaluate the risk with respect to the subrecipient institution and the subrecipient’s performance per the SOW. The evaluation will include the following:
    • Subrecipient Institutional Assessment: OSP will obtain a copy of the subrecipient’s Single Audit for the fiscal year in which the Subrecipient had an active subaward from the University. The Single Audit will be reviewed in compliance with Uniform Guidance.
    • Subaward (Project) Assessment: OSP will analyze a number of factors related to this issuance of a specific subaward, including the ratio of funds transferred to the Subrecipient, the SOW, COI, regulatory documentation and other factors.
  • Based on the results of the evaluation, OSP may or may not include additional terms in the Subaward.
  • Once the assessment is completed, OSP sends the draft to the Subrecipient, negotiates the terms, and executes the Subaward.
  • Notes:
    • No subaward will be issued until the applicable Subrecipient regulatory approvals have been received or their absence has been justified and appropriately documented.
    • Foreign Subrecipients performing Human Subject Research need to provide a current IRB approval and valid Federalwide Assurance (FWA) number, with an active registration.
    • Foreign Subrecipients performing research on animals may need to comply with additional requirements – contact the Institutional Animal Care and Use Committee.
  • Upon receipt of the SP-30 for a new subaward, OSP turns the requisition into an active Purchase Order (PO) in the University’s financial system once the subaward is fully-executed. The PO is created for the same amount obligated to the Subrecipient (Subrecipient’s budget including Direct and Indirect Costs).
  • Notification that the subaward has been fully-executed is distributed to the PI and the Department Administrator via ResearchUVA.
  • OSP receives all Subrecipient invoices and Financial Reports for initial review and forwards documents to the appropriate departmental contact for further processing. (See “Subrecipient Invoices” section).
  • In the event PI notifies OSP of Subrecipient nonperformance, OSP may at the direction of the PI: (a) provide Subrecipient with written notice of nonperformance and provide opportunity to address deficiencies, (b) terminate subaward for non-performance consistent with the terms of the agreement, and (c) take other action as appropriate and consistent with sponsor requirements.

Subrecipient Invoices

The Subrecipient is responsible for generating all invoices and maintaining proper documentation to substantiate charges. Invoices should adhere to the requirements included in the subaward agreement (e.g. state the subaward number, list line item detail of expenditures for the current billing period as well as the to-date cumulative total, achieved milestones, number of enrolled patients, etc.), and be sent via email to osp-subcontractorinvoice@virginia.edu to the Office of Sponsored Programs.

Additionally, in accordance with Uniform Guidance 200.305 “Payment”, when UVA is the pass through entity of federally awarded funds and engaged in a reimbursement type agreement UVA will issue payment for sub recipient invoices within 30 calendar days of receipt of a complete invoice.  The 30 day timeframe will not begin until UVA is in receipt of a complete invoice.

A complete invoice:

  • Contains all contractually required elements (i.e. UG certification, UVA subaward #, within period of performance, expenditure reports, cost share reports, etc.)

Please note there may be other legitimate reasons for an invoice not to be paid within 30 days

  • The Principal Investigator does not approve that the financial and/or technical aspects of the invoice accurately reflects the work completed and needs additional information
  • Sub recipient debarment or suspension by any federal department, elevated sub recipient risk level due to annual monitoring requiring remediation, etc.

Identified trends regarding invoice payments exceeding 30 days will be addressed with the responsible parties

Office of Sponsored Programs

  • OSP receives subrecipient invoice and enters it into an OSP tracking system. OSP sends invoice to the department for review, approval and payment, along with a transmittal letter stating that payment of the invoice confirms adequate technical performance on the part Subrecipient.

Principal Investigator

  • The PI reviews the invoice to confirm that the Subrecipient is performing according to the agreed upon SOW and approved budget.
  • The PI confirms that the expenditures fall within the project period and budget as stated in the Subaward, and that expenditures are reasonable and allowable according to progress.
  • After the PI has approved the invoice in writing, the departmental administrator will process the payment.

Department/School Administrator

  • Based on the approval of the PI, the department/school administrator receipts the invoice for payment using the correct line on the PO. The PI’s written approval to process payment should be attached to the PO in the University’s financial system.
  • Subrecipient payments may only be paid from an appropriately designated subaward PO in the University’s financial system. There are only two expenditure types that can be used, which are as follows:
    • Svcs, Subcontracts, Spon Prgm – to be used on the first $25,000.00 of expenses if applicable
    • Svcs, Subcontracts, OSP no F & A – typically used after the first $25,000.00 of expenditures

Example of the Invoice Payment Process:

  • UVA awards a subaward in the amount of $60,000 and budgets UVA F&A based on the first $25,000 of the subaward. Over the life of the project the Subrecipient bills UVA 3 times. The following expenditure types should be used when processing payments:
Amt Expenditure Type
Inv. No. 1-$20,000 $20,000 Svcs, Subcontracts, Spon Prgm (will burden F&A)
Inv. No. 2-$20,000 $ 5,000 Svcs, Subcontracts, Spon Prgm (will burden F&A)
  $15,000 Svcs, Subcontracts, OSP no F & A (won’t burden F&A)

FINAL 3-$20,000

$20,000 Svcs, Subcontracts, OSP no F & A (won’t burden F&A)

Closeout Process

The Principal Investigator

  • Upon acceptance of all required deliverables, PI will approve final payment to the Subrecipient.

School/Departmental Administrators

  • The Department will ensure the receipt of all reports required for close-out.
  • The Department will confirm by e-mail to OSP that all deliverables have been received.
  • The Department will work with the Post Award accountant to reconcile all subaward accounts with the Subrecipient’s final financial report.

Office of Sponsored Programs

  • After the close of a subaward, OSP will send an email to the Department Administrator with a copy to the PI, requesting confirmation that the Subrecipient performance was adequate and all required technical reports have been received.
  • OSP will ensure that the Subrecipient submits all final reports, A-133 certifications and the final invoice.
  • OSP may, per the terms of the subaward agreement, withhold final payment to the Subrecipient, pending receipt of all reports required at closeout including any outstanding A-133 certification letters.
  • OSP will work with the department to reconcile all subaward accounts with the Subrecipient’s final financial report.

End of Activity