Streamlining (sub)Award

ManagementOffice of Sponsored Programs

May 21, 2011ospoff@syr.edu

X2807

Help us learn about you◦ BBI’s organizational structure ◦ Folks’ roles/responsibilities◦ How you operate at various stages of the lifecycle

Review Sponsored Project lifecycle & guiding principles

Strategize on how to more efficiently work together to◦ Facilitate achieving the award’s goals & objectives while

adhering to sponsor’s requirements & SU policies / practices

Today’s goals… Get us all on the same page…

Spending Federal Dollars◦ Comes with strings attached◦ Want to avoid knots or the noose

Why??◦ Fed’s expectations: ??

At proposal submission – SU agrees to follow award’s terms and conditions including following SU policies/procedures, reporting requirements & the cost principles, which require that costs are:

Allowable – under terms of award and SU or entity policy Allocable – can reasonably determine benefit received by award and

cost proportional to benefit Reasonable – prudent person test (necessary) Consistently treated – either direct cost or indirect cost

Guiding principles

BBI’s organizational structure

Folks roles/responsibilities

How you operate at various stages of the lifecycle including communications & information management

About BBI

Find FOA ApplyNegotiate Award & Set up

Manage Award

Close-out & Repeat

or Recompet

e

The Sponsored Project LifecycleTransparency & Accountability to Avoid Fraud, Waste & Abuse

Find Funding Opportunities

BBI’s activities OSP

How & Who?

Go / no go process

Who notifies OSP (MMcB) about plans & when ?

COS

IRIS

Grants.gov / fbo.gov

Distribute to BBI leadership

Find FOA ApplyNegotiateAward & Set Up

Manage Award

Close-out & Repeat

or Recompet

e

The Sponsored Project LifecycleTransparency & Accountability to Avoid Fraud, Waste & Abuse

It’s a go – you’re going to apply

BBI OSP

Who’s responsible for what?

Needs◦ FOA information ASAP

URL PI & team Partners (non-SU)

Ltr of Com’tnt AOR SOW Budget required format

◦ Time to review & authorize 7 b-days: budget 3 b-days: complete app

◦ Service guidelines

You’re Applying….

BBI OSP

Internal Review◦ What is goal of project?◦ Who has expertise?

BBI? Collaborators?? What is each group doing? Cost? Parts and whole

◦ Info Management Version control Naming conventions

Reviews ◦ Application adherence

◦ IRR congruence

◦ Confirmation of 3rd party approvals

◦ FAR exceptions

◦ Lots of other stuff…

Submits

Decision to be made at proposal stage.◦ Not all treated the same in terms of F&A

◦ Regardless of Type of 3rd party relationship – In advance, have a SOW or at a minimum a clear understanding of what

they will do for you

◦ Characteristics of subrecipients, Vendors (purchased services) or consultants Lots of detailed information

Subrecipient ◦ Responsible for work and award performance◦ Subject to certifications/assurances (Human Subjects)

If at SU – would be PI or other key personnel

Subrecipient / Vendor / Consultant

Vendor◦ Services provided are core to their mission◦ Provide same services for many customers ◦ Price published or same rate for similar customers

May be non-profit organization Caveat – IHE’s procedures may impact agreement type

Consultant◦ Individual who provides advice or discrete service modest

scale A type of vendor in terms of award T&C (e.g., not subject to human

subjects assurances but may be subject to confidentiality provisions.) Is “work for hire”

◦ Use ‘worksheet for non-SU employees”

Subrecipient / Vendor / Consultant

Made up of many parts…

Much of our focus is on:

◦ Project plan – narrative, description etc Including Statement of Work (SOW)

◦ Budget

◦ Budget justification

Reminder - Application…

SOW vs Budget - two sides same coin -

BudgetSOWSOW

Budget is financial expression of statement of work (SOW).Work drives costs; each collaborator should define & “own” SOW

SOWs from each individual component

SUSub#1Sub#2Sub#3PurchSvc#1PurchSvc#2Cons't#1Cons't#2

Project Work Plan comprises…

Find FOA ApplyNegotiate & Set Up

AwardManage Award

Close-out & Repeat

or Recompet

e

The Sponsored Project LifecycleTransparency & Accountability to Avoid Fraud, Waste & Abuse

OSP responsibilities / tasks

BBI’s responsibilities / tasks

Subrecipient process under award management

Award Negotiation & Set Up

Grants / Contracts–

◦ Standard Terms & Conditions or Troublesome clauses (reviewed and identified at proposal submission)

◦ Where FAR exceptions accepted?

◦ Was there a modification to submitted budget or work plan? Adjust key personnel effort Modify scope of work Allowable costs?

Negotiate Award - OSP

Compliance check◦ Human subjects congruence◦ COI all folks◦ Debarment/suspension◦ IRR◦ etc

Award Set up - OSP

Common omissions delays… No Internal Routing and Review form

No current COI for key personnel

Human subjects protocols pending◦ Allocate $$ (easier if clear up front)

Human Subjects Not Human Subjects

Allocation of award to multiple SU units not clear

OSP OSA for Chartstring creation (new award)

OSP BBI PI, budget manager & project manager Award package: chartstring, T&C etc. New – OSP will confirm with BBI that any 3rd party

partners are the same as in proposal OSP will request institutional profile & conduct risk

assessment

After negotiation & compliance reviews… Award Set up - OSP

When GRANT agreement isn’t in hand – request as soon as known and practical

Contracts: only when we know start date and it’s not effective dated; high risk

Same compliance reviews as for awards

Not allowed◦ Subrecipient costs◦ Human subjects costs without congruence complete

What about forward funding?

Find FOA ApplyNegotiate

Award& Set Up

Manage Award

Close-out & Repeat

or Recompet

e

The Sponsored Project Lifecycle Transparency & Accountability to Avoid Fraud, Waste & Abuse

Manage the award - discussion

BBI OSP

Responsibilities◦ PI

◦ Day-to-day

◦ Financial

◦ Subrecipient

◦ Consultants

Information management

Negotiate amendments

Obtain sponsor prior approvals

Facilitate (sub)award administration

Facilitate compliance with SU / sponsor’s policies, T&C

Review all expected obligations upon receipt of award materials◦ ALL BBI personnel effort: review / revise upon receipt of every new

award and anticipated award.◦ 3rd party collaborations – plan ahead◦ Standing orders – plan ahead

Avoid confirming invoice attached

Not named folks debarment / suspension (epls.gov)

Review award materials especially terms and conditions to know what you can & can’t do.

DoL & cooperative agreements much less flexibility ◦ You can’t move named personal around at will. ◦ CONSIDER – name only essential folks

Award Mngt: Worth repeating…

Proposal Commitment:

SOWBudget &

Justification

Award –OSP BBI: Same 3rd parties?

BBI: Req 2 Issue & refine/ revise SoW & Budget

OSP: Request Profile & conduct risk assessment

OSP: Develop Subaward,Negotiate,Execute

Set up PO

Manage /monitor subawards

BBI: ProgressApprove $$OSP: costs, timing, pace

Subaward process Transparency & Accountability to Avoid Fraud, Waste & Abuse

From risk assessment, develop subaward◦ Cost reimbursable vs fixed price WHY

◦ Reporting requirements

◦ Financial supporting docs etc

Execute subagreement

Create PO in ePro

Set up in SADb

Send subagreement to BBI

Monitor ‘process’

Subrecipient Management - OSP

Managing your Award

Award Management Aid

Manage the (Sub)award – BBI discussion

Common challenges…and the consequences

Collaborators◦ Letters of commitment from authorized rep.

Partner may reject award Certs & Assurances not obtained from subaward delays

◦ Budget / budget justification Financial risk

◦ Statement of work missing or◦ Ambiguous standards of performance◦ Not unique to project

Errors in management “Braiding & Blending” allocobility concerns

Issue New subaward

Modify Existing subaward

Proposed- Subaward materials Transmittal

Deep Dive: Request to

Subaward Db - screenshot

Questions frequently asked of OSP

Why am I not being paid???◦ There is no agreement in place

No agreement – no obligation by SU

◦ No invoice has been received No invoice – no way to pay

Invoice review guidance

Other matters

Continuation…

And a year goes by….

Non-competing continuationsProcess varies by sponsor

BBI OSP

Annual Progress report

Complete ‘continuing application’

HINT: Work with sub’s same time to obtain updated SOWs and budgets for next budget period (~90d out)

Carry over?

Signs as authorized official or AOR, as required.

Reviews /approves budgets

Requests carry over, as applicable

OSP not informed of continuation process

Subaward continuation challenges

◦ Not done in a timely manner

◦ Ambiguous statement of work

◦ SOW similar to other awards

◦ Budget poorly justified with little linkage to SOW

◦ Inadequate budget justification

Baton gets dropped along the way – Communications / info management challenges◦ Agreement execution◦ Invoice management

Potential speed bumps

Formal process to ensure that all University obligations to sponsor have been met.◦ Programmatic

All required reports Invention reports

◦ Financial Final Financial report

Review all documentation Property Reports

◦ Subaward – as above

Close-out

Accepting federal $$ comes with MANY obligations, i.e there are strings attached.

Current administration –◦ Transparency and accountability to avoid Fraud, Waste, and

Abuse

Braiding and blending is not consistent with the allocobility cost principle

You will be audited. ◦ Following regulations, policies & SU procedures; timely actions; and

complete documentation are best protections against questioned costs, embarrassment, loss of reputation etc.

When bad things happen to good people

Late awards to SU◦ Impacts subawards◦ Effort Reporting◦ Cost transfers – too many, and not timely

Debarment & suspension◦ Must be done prior to hiring◦ Sub’s – we ask for certification, but they are

responsible for conducting epls check

Last audit

Effort – personnel compensation and supplemental pay (Extra Service) ◦ Subawardee effort procedures

Travel – especially foreign travel

Recharge Centers

Subrecipient monitoring

Administrative costs

Eligible activities

Future audits (IG work plans / A-133)

Accepting federal $$ brings with it the obligation to be responsible steward of those $$

Efficient and effective practices facilitate stewardship

Strategize / document what can we each do to support this goal…

Summary