subcontracts: deciphering espr taylor carl, osr melanie mkrdichian, department of surgery
TRANSCRIPT
Subcontracts: Deciphering ESPRTaylor Carl, OSR
Melanie Mkrdichian, Department of Surgery
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
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
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
How to log into ESPR
https://www.espr.northwestern.edu/
ESPR SUBCONTRACT REQUEST: NEW SUBAWARD
Tracking Number: Internal ESPR NumberInstitution Number: InfoEd Proposal Number• Make sure SP number matches the proposal subcontract requestRequest Created By: Who OSR will contact if they have any
questions and the person who OSR will cc on correspondence with the subrecipient
Chartstring: Make sure chartstring listed is correct• Chartstring listed in ESPR needs to match NU Financial Chartstring
Subaward Organization Name: Make sure Full Legal Name is listed• OSR reviews on SAM.gov to see if Subaward Organization has:
• 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 which organization is appropriate to award
the subaward
Subaward PI name: Make sure Subaward PI name matches the following• Budget• Budget Justification• Statement of Work
If there are discrepancies with the Subaward PI’s name, OSR will need to follow-up with person who made the request and, most likely, corrections will need to be made
Contact person: Preferably, the person at the subrecipient institution who’s in their central office• If this person is unknown or the subrecipient doesn’t have a central office,
then it should be the person who you’ve been working with at the subrecipient institution
Contact person email: Work email addressContact person phone number: Can only list 10 digit phone numbers. Please list international phone number in Additional info for OSR, if applicable
Amount of subcontract: Make sure approved budget uploaded in ESPR, the subrecipient’s budget in InfoEd, and Amount of subcontract are an exact match
Subaward cost share amount: If known, add cost share amount here• OSR will include cost share amount in subcontract
Anticipated Subaward project period: • Earliest start date can be the start of the 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 award• No later than authorized budget end date of prime’s period
– 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
If sponsor requires prior approval for subcontracts, additional questions will appear
If OSR will request sponsor approval for subcontract, additional information will need to be loaded into ESPR (Upload Other Sponsor Documents):• LOI• Letter to the Sponsor
Has the budget changed from proposed by more than 10%: Yes• Save Subcontract ESPR and complete a revised budget request ESPR
Allocated funds for subcontract: No• Load subaward budget and budget justification in Uploads section
– Click edit list of budget revisions*Note that budget revisions must be completed before the subaward is issued
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
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
If special reporting requirements are desired – click Yes• Text box will appear to add special reporting requirements• If language entered is confusing, OSR will contact ESPR requester to finalize
language that will be added to the subaward• Reporting requirements language may already be used in the subaward
boilerplate in which case we may not add any additional reporting requirements
• Additional reporting requirements are best utilized for subrecipients who need a large amount of monitoring
• It may be necessary to work with OSR and/or ASRSP to draft language for additional reporting requirements
If specific deliverables required– click Yes• Upload Deliverables, preferably in pdf• OSR will contact requester if there are any questions
Statement of Work (SOW): the detailed description of the work to be performed• Load SOW for subcontract site only• Preferably PDF should be loaded
Approved Budget: Make sure approved budget uploaded in ESPR, the subrecipient’s budget in InfoEd, and Amount of subcontract are an exact match
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 the subrecipient
listed in the ESPR• Preferably PDF should be loaded
Any additional Sponsor Documents that OSR may need because of sponsor’s requirements listed in the NoA, examples include:• Subrecipient’s IRB and/or ACUC approval• Work Plan• Letter to Sponsor
Human Subject/Animal involvement: Click yes or no depending if subaward site will have human subject/animal involvement
Subaward site will need ACUC or IRB approval sent to Northwestern prior to animal or human subject work to be completed
PHS compliant FCOI policy: No• ESPR asks for Subcontract PI’s name, DOB, email address• COI 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• NU’s COI Office link with sponsor’s who follow PHS FCOI policy:
– http://www.northwestern.edu/coi/policy/coi_by_sponsor.pdf
Additional info for OSR: text inserted here should be used if there are unique circumstances associated with the grant and/or subaward that would help streamline OSR’s issuance of the subaward• OSR will contact requester if there are any questions
Upload additional info for OSR• If possible, please upload complete Subrecipient Commitment Form
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 approvalsCancel & Back to Menu: Returns you back to Main Page
ESPR SUBCONTRACT REQUEST: SUBCONTRACT AMENDMENT
Make sure InfoEd number matches the proposal subcontract request
Project Chartstring: Make sure chartstring listed is correct• Chartstring listed in ESPR needs to match PAS
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
Subaward cost share amount: If known, add cost share amount here• OSR will include cost share amount in subcontract
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 & NUFS
• Make sure new budget period dates are in compliance with Notice of Grant Award
• 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
• A gap of time between the subaward’s budget period would 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• Budget period end date cannot go beyond NU’s current budget period end date
Modify Statement of work: Yes• Load new SOW for subrecipient• If SOW changes aims of project, sponsor approval will be needed
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
PHS compliant FCOI policy: No• ESPR asks for Subcontract PI’s name, DOB, email address• COI 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• NU’s COI Office link with sponsor’s who follow PHS FCOI policy:
– http://www.northwestern.edu/coi/policy/coi_by_sponsor.pdf
Upload Biosketch and Other Support
Change Subcontract funding: Yes• Amount of change can be positive or negative
– If negative, a detailed budget that incorporates the subtraction 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 detailed budget
Allocated funds for subcontract amendment: No• Load subaward budget and/or budget justification
– If both should be loaded, attach file request only allows one item to be attached
– Click edit list of budget revisions*Note that budget revisions must be completed before the subaward is issued
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
Carry forward automatically allowed on original subaward: YES• OSR will contact requester if there is carry forward confusion
Carry forward automatically allowed in original subaward: NO• ESPR requires approval from PI that carry forward on unobligated balance
Carry forward automatically allowed on Primary Award: YES
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• Upload a detailed budget for the carryover dollar amount
included in the ESPR• List new budget period dates
Carry forward automatically allowed on Primary Award: YES
Answering these two questions with a “No” means the subaward will not allow any carry forward for the subrecipient
Has carry forward for subaward been approved by sponsor: YES• List dollar amount that Sponsor approved for carry forward• Upload a detailed budget for the carryover dollar amount included in the ESPR• Upload sponsor’s approval of the carryover
Carry forward automatically allowed on Primary Award: NO
Carry forward automatically allowed: N/A• Should only be used if subcontract is ≤ 1 year
Carry forward automatically allowed on Primary Award: N/A
Complete just like Subcontract: New Subaward Request
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
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
QUESTIONS