i’m here for your audit. - university of delaware · • gain an understanding of the subaward...

I’m here for your audit.

Research 0

Subrecipient Monitoring

Sara Eastwick, Research Office

Portia Garvey, Research Office

Marlo Goss, College of Engineering, CBO

George Walueff, Procurement

Research 1

Research

Subrecipient Monitoring

Learning Objectives

• Understand Importance – the “WHY” behind subaward monitoring

• Gain an understanding of the Subaward Process from Proposal to

Close-Out

• Review Roles and Responsibilities Critical to Success

• Understand the Methods of Subaward Monitoring as Required by

OMB Circulars

• Obtain Valuable Tips, Tools, and Recommendations to Avoid Issues

and Delays

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What is Subrecipient Monitoring??

The process of providing oversight on subawards throughout the

lifecycle, including:

• Obtaining appropriate information prior to proposal

• Reviewing appropriateness of the subawardee

• Executing an agreement consistent with A-133 requirements

• Acquiring signed A-133 certification statements as appropriate

Research 4

What does A-133 require??

• Ensure that federal funds are used for authorized purposes in

accordance with laws, regulations and provisions of the prime

award.

• Ensure that performance goals are met.

• Monitor the activities of the subrecipient to ensure compliance.

Research 5

What does A-133 require??

• Ensure that subrecipients expending $500k or more annually have

met the audit requirements for that fiscal year.

• Issue a management decision on audit findings, if necessary, and

ensure that the subrecipient takes appropriate and timely corrective

action.

• Provide prime award information to subrecipients.

• Conduct on-going review and oversight of subrecipients progress

and compliance.

Research 6

Proposal Preparation

• Deciding at the proposal time if you are working with a sub,

consultant or vendor

• Not always obvious

• Do your homework

• Share chart with PI to help determine

• http://www.udel.edu/research/pdf/sub-v-consult.pdf

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• Per guidelines or prime award, can you work with foreign sub

• Special terms

• US Currency

• Export Control/Department of State

• Other (Close-Out Considerations, Property)

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Monitoring of

Subawards to Foreign Entities

Many Items to Consider

First Step – Subrecipeint? Are you sure?

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Characteristics

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• Substantive Programmatic Work

• Programmatic Decision Making Subrecipient

• Provides Goods & Services

• Many Different Purchasers Vendor

Fee for Service

• Work for Hire

• Performance Not Controlled Consultant

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Ok – It’s a Subaward

Now What?

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Subaward – Required Documentation

• Subreceipient Commitment Form

• Attachment 3B – Research Subaward Agreement – Subreceipent

Contacts

• Attachment 3B – Research Subaward Agreement - Page 2 Place of

Performance

• Statement of Work

• Budget

• Budget Justification

• Subs IDC Agreement

• Provider Category Determination Worksheet

• http://www.udel.edu/research/preparing/proposalguide.html

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Subaward Documents – Let’s take a look!

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Scope of Work

• Common elements of a successful scope of work for a subaward will

vary based on the project.

• A well written scope of work is crucial to the project in dealing with

possible obstacles or issues during the project.

• Research effort is based on a mutual understanding of the project

scope of work.

• It is understood that the subaward development proceeds in a

structured manner; each step is predicated on the approval of

previous steps and subject to project budget and scope

modifications

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Proposal Awarded!

• Awarded!!

• Recommend Meeting/Email/Discussion to include PI, SPC/Dept

Admin, and C&G Specialist

• Was the full budget awarded? Budget revision may need to be

done/routed. Has the budget awarded been reduced to change the

scope of work? Scope of Work may need to be amended.

• Check your cost share requirements! If budget was reduced so

should the cost share!

• Review Sponsor Terms & Conditions and COA!

• Review subaward documents to make sure they are in order

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Purchase Order Set Up

• Initiate requisition for subaward agreement after receipt of award

• Requisition is initiated by the department

• Requisition needs to be for the amount funded. If award is

incrementally funded, the requisition must only be for the amount

funded, not the full amount of the subaward.

• Attach Scope of Work and Determination Worksheet to the webform

before submitting.

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Procurement Services

After receiving a Requisition/Vendor Payment Request

• Reviews Provider Category Determination Worksheet

• Compares to the Statement of Work

• Obtains W-9 for tax id if not provided

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Procurement Services

Issues purchase order - PO becomes the subaward number to facilitate

payment

• Automated email goes to department with PO number

• Subrecipient does not receive a copy of procurement PO

• PO needs to be amended each time a new increment is

awarded.

• Purchase order remains open until a Purchase Order

Amendment Webform is received requesting closure.

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Subaward Package Assembled

• RO prepares documentation for submission to sub

• Based on assessment, sub is high risk, be creative –add

special requirements (reporting, auditing, special reviews,

milestones)

• Obtains approval from PI

• RO executes subaward documentation

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Subaward FFATA Reporting

• Federal Reporting Requirement - all subawards/

subcontracts over $25K (all subs issued after October

2010)

• Submitted by the RO

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Amendments

(Things to Consider)

• Are invoices received timely

• Carryover considerations

• Performance vs. Spending

• If above are issues, should you add special terms as a monitoring

mechanism (reporting, auditing, special reviews, milestones)

• Discuss with PI

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Invoicing

• Webform is initiated by the R/O for approval on all

invoices

• No longer using email approval

• Approvals include department, PI, and RO for Payment

• Checklist makes it easy to do it right!

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Subaward Monitoring

Checklist

- Each invoice needs to be

checked for accuracy!

- Use this checklist for each

invoice to check for compliance

- http://www.udel.edu/research/pd

f/training/subaward-monitoring-

checklist.pdf

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Questions to Ask During Monitoring

• Is the subrecipient’s work progressing according to

schedule?

• Are deliverables and reports being provided on time or in

a timely manner?

• Are all compliance considerations up-to-date?

• Are funds being spent according to the budget and within

the project timelines?

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Keeping on Track!

• Keep track of sub spending and invoice payments on UDataGlance

• UData will keep track of PO’s as an obligation

• Query can be used to view what has been committed and expended

for purchase order by PS Account.

- GMQ_PO_ACTIVITY_SUM

Research 27

Subaward Closeout Procedure

• Sub must submit final closeout paperwork

• Final invoice will be marked “FINAL”

• Final invoice paid

• Once final invoice is paid, the PO can be closed.

• Purchase Order Amendment needed to closeout PO. Once

amendment is received, Procurement can close the PO.

• PO’s that are not closed will populate in the ACR.

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SUMMARY

• Why Subrecipient Monitoring is Important

• A-133 Audit or Some Form of Audit Performed or Risk Assessment

• Determination – Sub vs. Consultant vs. Vendor

• Obtain Proposal Paperwork from Subawardee

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SUMMARY (cont’d)

• Receive Award – Initiate Requisition Webform

• Prepare Subawardee Documents

• Establish Special Requirements to Help With Monitoring

• Review Invoicing Documentation/Make Payment

• Close-Out Subawards

• Bottom Line - We All Play a Role in the Process

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