On July 26, 2018, members of the CSU RA community came together to view an NCURA webinar on “Managing Subawards Tips and Tricks.”  The presenters, Julie Callis, University of Maryland, and Laura Register, Stanford University, lead viewers through what’s required to effectively and responsibly manage subawards from compliance and practical perspectives, offering input from both central and departmental levels.

WHAT’S REQUIRED

Compliance with Uniform Guidance is required.  Sections detailing requirements related to subaward management include:

• Section 200.330 – Subrecipient and contractor determinations
• Section 200.331 – Requirements for pass-through entities
• Section 200.332 – Fixed amount subawards
• Section 200.333 – Retention requirements for records
• Section 200.512 – Report submission

The presenters reminded us of the order of precedence in that there may be sponsor specific requirements in terms of how to comply with UG.  For example, while foreign entities without an F&A rate can receive a de minimus rate of 10%, NIH still limits to 8%.

Bottom line: Check agency and program terms and conditions to ensure compliance in subaward issuance and management.

IMPLEMENTATION MUSTS

• Obtain prior approvals as required by the award terms, such as change of PI, rebudgeting, carryforward or adding or changing subawardees;
• Include required agreement information in the subaward agreement, including a copy of the prime agreement and flow down appropriate terms;
• Perform a risk assessment, either at time of proposal or award, to determine if additional monitoring is needed for particular subrecipients;
• Review subrecipient audit and ensure sub is retaining their documents for audit purposes; and
• Monitor the subrecipient to ensure they are invoicing in a timely manner and complying with agreement terms or with any corrective action plans that may be in place.

Bottom line: Uniform guidance, federal tax laws, and institutional policies and practices require we properly categorize subrecipients (as opposed to contractors), flow down appropriate terms, and determine the ability of the subrecipient to properly management federal funds.

IMPLEMENTATION BEST PRACTICES

Depending on the pass-through entity’s assessment of risk posed by the subrecipient, Callis and Register recommended the following best practices for ensuring compliance with program requirements and for successful project implementation:

• Provide subrecipients with training and technical assistance on program-related matters;
• Perform on-site reviews of the sub’s program operations (on-site review for programmatic compliance may be conducted by the Prime’s PI; desk audit of financials may be conducted by the Prime’s central office);
• Verify subrecipient audit as set forth in § 200.501 Audit requirements;
• Consider whether the results of the sub’s audits, on-site reviews, or other monitoring activities indicate conditions that necessitate adjustments to the pass-through entity’s own records; and
• Consider taking enforcement action against noncompliant subrecipients as described in § 200.338 Remedies for noncompliance.

Bottom line: Callis and Register reminded the audience that a smooth subaward begins at the proposal stage- with a clear scope of work unique to each subrecipient; a budget that aligns with the scope of work; clear documentation when making the determination between subrecipient and contractor; and open lines of communication between PIs, departments, central offices and prime and sub entities.

MONITORING & OPEN COMMUNICATION- KEY TAKEAWAYS

The key take home message was “Communication is key,” –cross communication and training between central and department administrators; communication between faculty and administrators, and communication between prime awardee and subawardees, with a focus on needs and impact.

Being aware of the regulations, while establishing published processes, procedures, and key contact lists will help ensure people are resourced for making informed decisions and knowing where to turn for assistance.