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Subaward Basics

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04/28/2017 - 12:06pm

FTP Expanded Clearinghouse Pilot

Frequently Asked Questions

 

ASU PARTICIPATING IN THE FEDERAL DEMONSTRATION PARTNERSHIP EXPANDED CLEARINGHOUSE PILOT

“ASU is participating in the Federal Demonstration Partnerships’ (FDP) Expanded Clearinghouse pilot with approximately 105 other institutions.  The charge of this pilot is to develop one single web based repository for all FDP entities to enter, upload, maintain and update all entity related information about their organization.  Before the pilot, ASU always requested this information via the Subrecipient Commitment Form. Now it only requests the subrecipient commitment form from non-pilot institutions.  For pilot participants, ASU requests abbreviated information using the Subrecipient Letter of Commitment.


Questions and Answers

Q: How can I l find the list of institutions participating in the pilot?

A: See the FDP Expanded Clearinghouse Institutions list.  

Q:  At the proposal, what form should I request from a subrecipient?

A:  If they are part of the FDP Expanded Clearinghouse Pilot, ask them to complete the Subrecipient Letter of Commitment.  If they are not part of the FDP Clearinghouse Pilot, send them the Subrecipient Commitment Form.

Q:  Many subrecipients have different points of contact for each project. How will we capture this information if they are part of the FDP Expanded Clearinghouse Pilot?

A:  The entity profiles contained in the FDP Expanded Clearinghouse lists several contacts including: Authorized Official, Financial Officer, F&A Rate Negotiator, Audit Contact, SAM Contact and FFATA Contact.

Q:  What if we are submitting a proposal to a pilot institution and they request we complete their Subrecipient Commitment Form?

A: Send the following suggested language:  

I am writing to let you know that Arizona State University is a pilot participant in the FDP Expanded Clearinghouse.   It is my understanding that your organization is also a participant.   As part of the pilot, both of our organizations have agreed that we will not send nor require completion of a subrecipient commitment form but will instead use our profile which is posted on line at the FDP Clearinghouse FDP Institution list.

Please use our institution’s profile to obtain the information you require.  If there is information beyond what can be found in our profile that you need, please let me know the specifics.

Q:  Who do I contact if I have questions regarding the FDP Expanded Clearinghouse Pilot?

A:  Send any questions or concerns regarding this pilot to Subawards [at] asu [dot] edu.

 

FREQUENTLY ASKED QUESTIONS

What is a subaward?

A subaward is a legally binding agreement issued when a substantive portion of the sponsored project will be performed by another entity.

When should a subaward be issued to another entity?

ASU issues subawards to other entities when they will be working in collaboration with an ASU PI to perform a substantive portion of a grant or contract’s programmatic effort.   To determine if ASU will need to enter into a subaward, consult the Subrecipient vs. Vendor/Contractor vs. Consultant tool.

ASU issues subawards, does it also receive subawards?

Yes.  When another entity wants ASU to assist them in fulfilling a substantive portion of their externally funded sponsored research, they will issue a subaward to ASU.

What is a sole source justification?

A sole source justification is an explanation of why a subrecipient is uniquely qualified for this particular project.   Cost alone is not a satisfactory reason.   It must also address the technical expertise of the Subrecipient PI.

Are there different kinds of subaward agreements?

Yes.   Subawards are issued as cost reimbursable or fixed price.   A cost reimbursable agreement is based on actual project expenditures incurred during the performance period, up to an agreed amount.  Fixed price agreements are issued when performance is based on deliverables, each of which is assigned a lump sum amount.

What generally determines the type of subaward ASU will issue?

The type of subaward is determined on the individual factors of project.   However the following is illustrative of when it might be one type of the other:

Cost Reimbursement Subawards Fixed Price Subawards
The prime award made to ASU is cost reimbursable The prime award made to ASU is fixed price
The subrecipient is a domestic entity

The  subrecipient is a foreign entity

The subrecipient assessment risk level is low The subrecipient risk level is high

 

 

 

 

 

 

When might a subrecipient be classified as HIGH risk?

Each subrecipient is assessed for risk prior to the issuance of a subaward agreement.  Reasons for a high risk designation include, but are not limited to:

  • Foreign entities that are governed by laws, regulations, and financial systems which do not align with the United States
  • Domestic entities with significant audit findings without a defined corrective action plan
  • Subrecipients without an external audit, internal control policies, or a sound financial system
  • Subrecipients where ASU will have limited visibility into the subawardee's operations

 

DOES ASU ISSUE A LOT OF FIXED PRICE SUBAWARDS?

Approximately 10% of all subawards issued are fixed price.  The other 90% are cost-reimbursable.

 

WHEN MIGHT A FIXED PRICE SUBAWARD BE APPROPRIATE?

Generally fixed price subawards are issued when:

  • The award to ASU is fixed price
  • The subrecipient is classified as high risk
  • The subrecipient is a foreign entity
  • The subrecipient is required to provide specific deliverables in addition to, or in lieu of, technical reports

 

IF A FIXED PRICE SUBAWARD IS ANTICIPATED, SHOULD IT BE INCLUDED IN THE BUDGET?

Yes, it will facilitate sponsor approval at award time.

 

IS IT NECESSARY TO JUSTIFY FIXED PRICE SUBAWARDS IN THE PROPOSALS

Justification for the fixed price subaward should be included.  The following language is recommended in the budget justification:  “ASU anticipates the issuance of a fixed price subaward to [Name the subrecipient here] documented in this proposal and is requesting prior agency approval.  This Subrecipient meets the criteria described in Subpart C- 200.201(b) and if this proposal is awarded, ASU will consider this subaward approved.”

 

IS THERE ANY DOLLAR LIMITATION ON THE AMOUNT OF A FIXED PRICE SUBAWARD?

Yes, fixed price subawards may not exceed $150K, including supplements and modifications.

 

DOES ASU HAVE A PROCESS TO ADDRESS THE FIXED PRICE SUBAWARD LIMITATION?

Yes, ASU will issue multiple subawards with separate and distinct scope of works.

 

WHAT SHOULD BE DONE IF A FIXED PRICE SUBAWARD WILL EXCEED THE $150 THRESHOLD?

If it is known at proposal time, contact the assigned PNT GCO to discuss options.   If it comes up after the award, contact the assigned AMT GCO for guidance.  

 

WHAT IS REQUIRED BEFORE asu CAN ISSUE a subaward?

Both proposed cost reimbursable and fixed price subawards need to be clearly described in the subrecipient's scope of work; clearly outlining subrecipient responsibilities, required deliverables, and specific due dates for each milestone. Wherever possible, the request for subaward should be included in the proposal to expedite sponsor approvals, where required.

 

DOES THE FEDERAL GOVERNMENT IMPOSE ANY ADDITIONAL REQUIREMENTS?

For fixed price subawards to be issued using federal/federal flow through funds, sponsor approval is required. There is also a cost limitation on fixed price subawards which caps at $150,000.  Federal sponsors do not have the ability to approve over the cap fixed price subawards.

 

WHAT IF A SUBAWARD IS REQUIRED BUT WAS NOT BUDGETED IN THE PROPOSAL?

Many sponsors, though not all, require prior approval to add a subaward that was not budgeted.   If prior approval is required by the sponsor then an OAF must be completed and submitted to notifications [at] asu [dot] edu. After review, the Awards Management team GCO will forward the request to the sponsor.  If no prior approval is required, the ORSPA Action Form (OAF) will trigger the establishment of a child account and the beginning of the subawards issuance process.

WHERE SHOULD THE OAF BE SENT FOR ISSUANCE OF A SUBAWARD NOT BUDGETED IN THE PROPOSAL?

The fully justified and completed OAF should be sent  to notifications [at] asu [dot] edu, regardless of whether prior sponsor approval is needed or not.  The following should be attached:  Subrecipient Commitment Form or for pilot participants Subrecipient Letter of Commitment, Scope of work, budget/budget justification, deliverables, and other terms the PI needs included in the subaward.

 

Who has primary responsibility for an ASU issued subaward?

Issuing and monitoring subawards is a joint responsibility lead by the PI.

 

Why is it important for the PI to have regular contact with the Subrecipient PI?

Regular contact will allow the ASU PI:

  • to ensure that the subaward objectives/scope of work is proceeding as planned and described to the sponsor.
  • to monitor the quality of work being submitted and identify issues that arise in a timely manner.
  • to facilitate review of invoices for reasonableness, allowability and allocability.

WHAT ARE THE RESPONSIBILITIES OF THE SUBAWARD PI?

  • Makes programmatic decisions and controls the method of work, as needed, in order to complete the scope of work outlined by ASU in the subaward agreement.
  • Expends funds and manages the project in accordance with all applicable ASU and prime sponsor requirements.

WHAT IS THE BEST WAY TO ENSURE THE SUBAWARDS PROCESS IS MANAGEABLE FOR THE PI?

  • Ensure the scope of work is clear up front.   By this it is meant that the scope of work describes only the portion of the work the subaward PI is responsible for, that it is clearly outlined by specific objective and that any deliverables, such as reports, have been clearly identified.
  • The ASU PI is also responsible for the receipt and review of technical reports and other deliverables submitted by the subrecipient.  Before providing approval to process an invoice, it is critical that the PI has received the required results and deliverables.   This is the only opportunity to hold the other institution responsible for the work they were subcontracted to do.

What steps can an RA take to assist the ASU PI in working with other entities?

  • Ensure that the PI is aware of the ASU requirements, including the need to seek the other entity’s approval before including their work in the ASU proposal
  • Assess the potential risk associated with issuing a subaward to other entity.
  • Assist the PI in preparing what the non ASU entity should include in their scope of work
  • Obtain the contact information for the administrative contact at the other entity
  • Contact the other entity’s administrative contact early to provide guidance on the required documentation needed to initiate a subaward, including upcoming deadlines.

If the subawardee’s work occurs early in the project, delays in obtaining the executed subaward agreement with the non ASU PI’s institution can significantly hinder the ASU PI’s work.   Following the above steps can help alleviate delays.

 

WHY IS IT IMPORTANT TO OBTAIN SUBRECIPIENT INSTITUTIONAL APPROVAL AT THE TIME OF PROPOSAL?

It might be tempting to await word that an award is forthcoming prior to obtaining official subrecipient documents, but delaying in this way can cause a number of issues:

  • The subawardee (aka as subrecipient) can decline to participate in the project if they did not sign off on their institution’s inclusion in the proposal.
  • The budget may not be accurate, potentially impacting the ASU PI who may need to pay for additional costs out of their own project to meet the subawardee’s institutional policies.
  • The subaward issuance may be significantly delayed while the RA seeks the required documents.
  • If the subawardee is new to federal support, registering and waiting approvals for the SAM system can potentially result in delays
  • If the research includes human or animal subjects, the subrecipient will need IRB/IACUC approvals, which can result in a time delay.
  • If the sponsor requires PS FCOI Compliance and the subrecipient is not compliant, a delay in issuing the agreement can occur.
  • If the subawardee’s work occurs early in the project, delays in getting the executed subaward agreement with the non-ASU PI’s institution can significantly hinder the ASU PI’s work.  

Ensuring that all paperwork is received timely can help alleviate delays.

WHY DOES ASU SOMETIMES REQUEST A SUBRECIPIENT FORM?  aND OTHER TIMES A SUBRECIPIENT LETTER OF COMMITMENT?

ASU is participating in the Federal Demonstration Partnerships’ (FDP) Expanded Clearinghouse pilot with approximately 105 other institutions.  Before the pilot, ASU always requested this information via the Subrecipient Commitment Form. Now it only requests the Subrecipient Commitment Form from non-pilot institutions.  For pilot participants, ASU requests abbreviated information using the Subrecipient Letter of Commitment.  To learn more about the pilot and to identify other pilot institutions, visit the FDP Expanded Clearinghouse.  For any questions or concerns regarding this pilot, contact subawards [at] asu [dot] edu (subject: Subrecipient%20Form%20Vs%20Subrecipient%20Letter%20of%20Commitment) .

How should the subaward scope of work be written?

The scope of work should not be a reiteration of the overall proposal being submitted.   Rather it should define only the specific work to be performed by the subrecipient.   Within this scope of work, it is important that the tasks to be performed are clearly outlined and that any expectations for reports or deliverables are listed.  The scope of work is going to be part of the legally binding agreement that will be issued.   This document is the basis for determining the timeline for expected progress and how the research will move forward .   If the scope of work is unclear, it can lead to confusion, misunderstandings, or  grants that cannot/do not meet their objectives.

Are there any complications in working with foreign subrecipients?

Working with foreign subrecipients can be challenging.   They often do not have processes which parallel those in the United States.   This may create difficulties completing the Subrecipient Commitment Form.   Working early with PNT's Subaward Team to determine what information will be required when the subrecipient does not have the same practices can save time and alleviate potential problems.

Do foreign subrecipients need DUNS numbers?  Must they be registered in SAM?

A DUNS number and registration in SAM are federal requirements for participating in projects funded by US government funds. One suggestion here is to help the foreign subrecipient’s administrative contact with the registration process by clearly explaining what they need to do to register.   Navigating through United States' regulations can be difficult for the foreign subrecipient and may lead to significant delays for the project. If the PI speaks their language, he/she may need to assist with translation.

Can funds be advanced to foreign subrecipients?

Foreign subrecipients generally need to be provided funds at the start of the project.  Many do not have the ability to do the work prior to receiving these funds.   To assist with this, foreign subawards can generally be issued a fixed price agreement where a portion of the funds are given upfront with the balance provided on a specific schedule of concrete deliverables.   For this reason, it is critical that the scope of work be specifically worded to accommodate this type of arrangement.

 

 

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