subawards and the uniform guidance research reps meeting 17 march 2015
TRANSCRIPT
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Subawards and the Uniform Guidance
Research Reps Meeting 17 March 2015
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Introduction
• Uniform Guidance requires Pass Through Entities [PTEs] to develop Subrecipient Plans
• At UWM, divided into four phases
PROPOSAL DEVELOPMENT
AND SUBMISSION
SUBAWARD IMPLEMENTATI
ON
PROJECT PERFORMANCE
AWARD CLOSEOUT
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Overview• Subrecipients versus Contractors
– Subrecipients include those entities that• Have responsibility for programmatic decision-making• Measures performance in related to the prime award• Funds and carries out its own programs• Requires unique expertise of subrecipient personnel• May be included as co-authors or publish their own work• Perform work with human subjects or animals
– Contractors include those entities that• Provide goods and services within the normal scope of operations• Provides “off the shelf” goods/services to many different purchasers• Operate in a competitive environment• Provides services that are repetitive in nature• Assumes the risk if performance is more costly and/or time consuming than expected
• Subcontractor Selection Remains the PI’s Responsibility
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Proposal Development and Submission
• Information Requested from Subrecipients– Scope of Work– Budget/Budget Justification– Letter of Commitment – De Minimis Rate Agreement (if no negotiated F&A
Rate Agreement)
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Subaward Implementation
• UWM has developed questionnaires for subrecipients to complete at time of award
• Data is used to determine the type and structure of the subaward agreement
• OSP will be responsible for obtaining info from subrecipient and developing the subaward agreement
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Subrecipient Monitoring• Data from the questionnaire (at time of award and
annually) determines monitoring strategies and are included in the Subaward Agreement. May request:– More frequent invoicing – Information on Single Audit Findings – More frequent technical reporting– Provide training/technical assistance to subrecipient
• Additional Review during Invoice – Ensure “the science matches the spending”
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Award Closeout
• Subrecipients must provide their final invoices and account for real/intellectual property within 45 or 60 days from the end of the project
• Subrecipient responsible for notifying UWM immediately if costs are later disallowed during an audit
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Conclusion
• Subaward Guides forthcoming:– UWM Principal Investigators – Subrecipients
• Questions?– Send to [email protected]