nih subrecipient monitoring

The PDF template has been updated in . Upon receipt of the partially executed subaward agreement/amendment, coordinates OSP signature and returns the fully executed subaward . Subawards & Subrecipient Monitoring A Subaward is an award issued under a larger sponsored projects award for the procurement of specific services or program-related tasks. NSF Current and Pending Form (Template) Request for Cost Sharing. Subrecipient Monitoring Procedure and Checklist In accordance with 2 CFR 200, the "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, the Office of Sponsored Programs (OSP) has developed this procedure and checklist for subawards issued under federal assistance agreements. Subrecipient Monitoring. Contracting Forms and Templates. If scientific progress is not satisfactory, or if technical reports required of the Subrecipient are not prepared timely, the PI is responsible for contacting the Subrecipient to address these issues. A s the prime recipient the pass-through entity is ultimately responsible for the subrecipient's performance and compliance with federal and state regulations and . PROPOSAL PREPARATION: SUBAWARD MONITORING: PI requests proposal package from proposed subrecipeint, to include: Scope of Work - specific to the subrecipient Budget and Justification - specific to the subrecipient Subrecipient Commitment Form, MCA Form or FDP Form (as applicable) signed by the subrecipient's authorized official PHS or non-PHS Conflict of Interest Form(if applicable, see . A subaward is a contractual agreement utilized when a portion of work benefitting a University of Nevada, Reno (University) sponsored project is allocated to an external entity, i.e., a subrecipient. Subrecipient monitoring procedure. Compensation and HR Task Force Administrative & Clerical Policy for Salaries on Sponsored Funds Agency Guidelines & Updates Uniform Guidance: Published Document. OMB . Use for: Arrival, Departure or Changes in PI/Key Personnel Named in Notice of Award (including multi-PI arrangements), Reduction in Effort of those PIs/Key Personnel of 25% or more (this includes changes submitted on the RPPR). LANL is responsible for monitoring subrecipient's compliance with the The use of these tools and scope of monitoring procedures should be determined by the PI and administrators based on the nature of the grant and the perceived risk associated with the subrecipient. Please note, this list does not include all sponsor- or program-specific requirements (e.g., human subject assurances). That plan should include a schedule for monitoring, documents and reporting . 2/16/2022 - Updated Subawards FAQs # 3 and #4. The Devil is in the Details. Sample Proposal Coversheet. At the end of each module, participants are asked . This document outlines the pre- and post-award requirements for . NIH Grants Policy Statement HHS Grants Policy Statement NSF Grants Policy Guide EFFECTIVE DATE This CCHIP is effective as of the date of revision and rescinds all previous versions pertaining to the Subrecipient Monitoring of Sponsored Projects. Mission. NIH monitors recipient expenditures under individual grants within each budget period and within the overall project period. PROPOSAL PREPARATION: SUBAWARD MONITORING: PI requests proposal package from proposed subrecipeint, to include: Scope of Work - specific to the subrecipient Budget and Justification - specific to the subrecipient Subrecipient Commitment Form, MCA Form or FDP Form (as applicable) signed by the subrecipient's authorized official PHS or non-PHS Conflict of Interest Form(if applicable, see . Subaward Relationship. Subcontractor shall ensure that all personnel participating in the Project complete the National Institutes of Health education requirement on the protection of human subjects, addressed in NIH Notice OD-00-039. Office of Management Assessment, National Institutes of Health, 6705 Rockledge Dr. Suite 601 Bethesda, MD 20892 Looking at Healthy Vision Month in a New Light; Six Things to . Subrecipient Monitoring . The subaward is entered into by the University and the subrecipient and sets forth the terms and conditions for the subrecipient's proposed . U.S. Department of Health and Human Services. In most cases, a subrecipient award will be for a particular phase or area of a sponsored project which has been identified in both the proposal and subsequent . Subrecipient Monitoring Program MIT is responsible for monitoring the programmatic and financial activities of its subrecipients in order to ensure proper stewardship of sponsor funds. For NSF and Non-PHS agencies: Subrecipient Organization/ Institution certifies that it has an active and enforced conflict of interest policy that is consistent with the provision of 42 CFR Part 50, Subpart F "Responsibility of Applicants for Promoting Objectivity in Research." Subrecipient also . Definitions Award: An award is a binding agreement between an external sponsor and Purdue University to support research, instruction, training, service, or other scholarly activities with . Additional forms and templates Research or Conference Account Request (RCAR), See BPPM 40.07 Research or . Compensation and HR Task Force Administrative & Clerical Policy for Salaries on Sponsored Funds Agency Guidelines & Updates Uniform Guidance: Published Document. Subrecipient Monitoring; To find the right OSPA representative for your need, please view our assignment matrix. Program Officers Review any actions that might suggest a change in scope, for example, a new subaward or change in an existing subaward. To be an effective tool for avoiding problems and improving performance, monitoring must be an on-going process. Subrecipient monitoring includes verification of receipt of interim and final reports submitted in accordance with the subaward scope of work. L. No. The PI must either approve or disapprove payment of the invoice. Site Visit Program. Alliance began this formal subrecipient monitoring policy in 2016 as per OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) ("Uniform Guidance"), specifically §200.331." 2. Characteristics which support the classification of the non-federal entity as a subrecipient include when the non-federal entity: (1) Determines who is eligible to receive what . Subrecipient Monitoring Template. Subrecipient Monitoring • Subrecipient monitoring is a series of controls, policies, procedures, and best practices put in place to ensure the compliant use of pass-through federal funding to entities performing intellectually significant work for the benefit of an overall project. 1/25/2022 - added three new FAQs related to subrecipients in the Subawards section below.. 8/19/2021 - See Update: NIH Other Support and Biosketches and the latest FAQs.. 6/28/2021 - The following FAQs related to the NIH Other Support format pages and Biographical Sketches were collected from researchers . • This is achieved through the monitoring of subrecipient activities and financial stability to identify and . Subrecipient monitoring Monitoring includes expectations of the principal investigator, fiscal officer, and the Office of Research Administration. Audit Yale • Based on deficiencies of earlier audit & unfortunate communication . This change is being made to preserve an "arm's length" relationship between Syracuse University and every subrecipient. The purpose of this document is to provide guidance and resources to assist with the monitoring process. Subrecipient Monitoring & Risk Assessment Guidelines. All key stakeholders share this responsibility. A Subaward is an award issued under a larger sponsored projects award for the procurement of specific services or program-related tasks. Subrecipient Monitoring & Risk Assessment Guidelines. Grants Management Set Up An Award; Manage Your Award; Close Out Your Award; Subrecipient Monitoring; CONTACT For more information or assistance with awards, please contact: Office of Sponsored Programs Administration . Proposal/Award Cores: Phone: 502.852.3788 Fax: 502.852.8429 OSPA . The obligation to "monitor" subrecipients is nothing new; the OMB Uniform Guidance (including its predecessor OMB Circulars A-110, A-133, A-21, and A-122) and the NIH Grants Policy Statement have long maintained subrecipient monitoring as a fundamental obligation of prime awardees. Not applicable because this project is not being funded by NSF or PHS (NIH, CDC, AHRQ, etc.) Establishing Subawards Subawards are issued only after a fully executed Award is received by OSP from the Sponsor and the Award is setup in OFC. The University must consider: Subrecipient's prior experience (including lack of performance)? UAB Policy - Establishing a Subrecipient Agreement. Subrecipient Management. All key stakeholders share this responsibility. Need more information? The session will focus on the administrative aspects of subrecipient monitoring. This subaward sample has been created to assist in issuing fixed-rate subawards to enrolling sites under NIH-funded clinical trials/clinical research. However . National Institutes of Health (NIH) Food and Drug Administration (FDA) Centers for Disease Control and Prevention (CDC) Agency for Healthcare Research and Quality (AHRQ) Agency for Toxic Substances and Disease Registry (ATSDR) Indian Health Service (IHS) Substance Abuse and Mental Health Services Admin (SAMHSA) Health Resources and Services Administration (HRSA) Further information regarding . Issuance of a Subaward under a federal prime award is subject to compliance with federal law. She has presented on Subrecipient Management and Monitoring over 15 times in the last 5 years at national, regional and local conferences in the field of research administration. USA.Gov - Government Made Easy. Salary Cap Worksheet. A subrecipient may also be a recipient of other Federal awards directly from a Federal awarding agency." 1.2.2. In addition, please feel free to reach out to your assigned Grants and Contracts Officer, or HMS SPA's Associate Director of Grants and Contracts, Melissa Korf, with questions on subawards/subrecipient monitoring. NIH Certification about Safe and Healthful Work Environment. Therefore, specific due dates for interim and/or final reports to UAF or the sponsor should be included in this section. (1) Provides goods and services within normal business operations. Subrecipient Monitoring 32 Risk Assessment Timed Monitoring Pre-award During-the-award Monitoring Post-award Monitoring Emory Unit Monitoring OSP PI RAS/Department/Business Administrator/College OGCA. Subrecipient institutions that must comply with LANL's policy must submit all Investigator disclosures of Significant Financial Interests to LANL in sufficient time to allow for LANL to review, manage and report identified FCOIs to the NIH. 104-156)), which directs that each Prime Recipient is responsible for monitoring its Subrecipient's use of federal funds; 2. Innovations for Poverty Action (IPA) is responsible for monitoring the programmatic and financial activities of its subrecipients to ensure proper stewardship of grant funds and compliance with donor and other legal requirements. VII. Not applicable because this project is not being funded by NSF or PHS (NIH, CDC, AHRQ, etc.) As a result, our Subrecipient Monitoring Program has been expanded to meet these requirements. Yes No NIH: Subrecipient Organization will monitor and maintain records of individual RCR training plans in accordance with NIH's RCR training requirements for NIH Grants for Training and Fellowship awards. 4. DOJ, HHS, DOD, NSF, NASA et al. Site Visit Results Letter. (1) Determines who is eligible to receive what federal assistance. Ensure the costs are reasonable (e.g. Contractor. Effective July 1, 2019, the Office of Sponsored Programs (OSP) will no longer accept subrecipient invoices forwarded from parties other than the authorized financial representative of the subrecipient entity. After Rice receives the award and prior to issuing a subaward, SPARC performs and documents a risk assessment of the subrecipient organization to determine the level of risk and the extent of monitoring . For any sponsored research project awarded to a PI in The Texas A&M University System that involves an external, third party to . Please note, this sample should be modified only if necessary according to your NIH award. Risk Assessment 33 Purpose: Identify potential risk exposure early so appropriate monitoring . Contact Us: HMS_SubMonitoring@hms.harvard.edu. Subrecipient Monitoring Procedures Revised: November 2015 1 Subrecipient Monitoring Procedures This procedure describes the proper management of subrecipient activity under Purdue sponsored program awards. Subrecipient risk assessment Subrecipient relationships involve a certain amount of risk. . Donna is experienced in public speaking, project management, regulation interpretation and policy development. Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Uniform Guidance - Joint Interim Final Rule Office of Management and Budget. The level of MSU oversight varies by subrecipient and/or subaward, depending on the relative risk of noncompliance and nonperformance that each subrecipient or agreement presents. Find criteria in the NIH Grants Policy Statement (GPS) Section 8.4.1.5.5, Recipient Reporting of Subrecipient Data and Executive Compensation Information for FFATA. Grants and Federal Resources Team (GFRT), Governor's Office of Strategic Planning and Budgeting (OSPB) 1700 West Washington Street, Suite 600 . addition, the University must comply with the Subrecipient monitoring requirements specifically contained in the following: 1. MSU subrecipient monitoring procedures include an annual risk assessment of each subrecipient with a current subaward from MSU, as well as an . in line with the amount of work being reported or deliverables submitted), allowable in accordance with the cost principles, and incurred . For NIH grants, all first-tier subawards, including foreign sites, must have a DUNS number. UW's subrecipient monitoring requirements are comprised, at a minimum, of the following: Completion of the UW's entity level comprehensive risk assessment (Certs & Reps, Annual Audit Certification); UW approved systems must be used to request issuance, renewal or modification of a subaward; The frequency and intensity of monitoring are based on the risk assessment performed at the time of the initial subcontract and any changes to that assessment during the life of the subaward. Subrecipient Monitoring Plan and Procedures Monitoring of subrecipients should not be a one-time event. Subrecipient monitoring is required by Harvard University's Subrecipient Monitoring Policy and is an essential element of sponsored funding stewardship. Prior to submitting a University proposal to a Federal sponsor that includes the above defined subrecipient, the Office of Research Services will ensure that the subrecipient has supplied the University with a letter of intent signed by an authorized institutional official or, in the case of proposals to Federal sponsors that utilize the Grants.gov portal for submission, a completed and signed . Matrix of Compliance Requirements Contact Us . For reference: Subrecipient monitoring is required by Harvard University's Subrecipient Monitoring Policy and is an essential element of sponsored funding stewardship. Subrecipient Monitoring - Activities performed by the pass-through-entity to ensure that subagreements are used for authorized purposes in compliance with laws, guidelines, and the provisions of the sponsored project and that performance goals are achieved; includes reviewing organizational and financial data in the proposal stage to identify potential risks; annual monitoring post-award may . For NSF and Non-PHS agencies: Subrecipient Organization/ Institution certifies that it has an active and enforced conflict of interest policy that is consistent with the provision of 42 CFR Part 50, Subpart F "Responsibility of Applicants for Promoting Objectivity in Research." Subrecipient also . Rice University's Office of Sponsored Projects and Research Compliance (SPARC) is committed to supporting the research endeavors of faculty members and staff and helping them understand their obligations and ensure compliance with applicable governmental regulations and university policies.. What we do. The UAB Letter of Intent to Establish Subaward should be submitted for each subaward at the time the application is submitted to the sponsoring agency at osp@uab.edu. Concerns or questions with regards to implementing this should be directed to SPA. Joseph M. Gindhart Associate Vice Chancellor for Finance & Sponsored Projects . If the subrecipient's Investigators must comply with the subrecipient's Financial Conflict of Interest policy, the written agreement shall specify time period (s) for the subrecipient to report all identified Financial Conflicts of Interest to the awardee Institution. Subrecipient monitoring reduces the risk of doing business with an external entity. Once awarded, department personnel should submit the UAB Federal Grant Subaward Request Form. • This is achieved through the monitoring of subrecipient activities and financial stability to identify and . This 60 minute course provides a high-level overview of monitoring subrecipients and is intended for grantees that make subawards. Unless otherwise dictated by the federal sponsor, this rate is available to both domestic and foreign subrecipients (e.g., NIH caps foreign subrecipients at 8% MTDC). This session is meant to be highly interactive, please bring any unique . All Subawards are subject to the terms and conditions of the larger sponsored projects award and the normal . Sample Subrecipient Monitoring Risk Assessment Tool Author: Office of the Chief Financial Officer $OCFO$ Subject: financial management Keywords: grantee compliance, grant provisions, federal requirements, financial management, Sample Subrecipient Monitoring Risk Assessment Tool Created Date: 6/21/2019 10:05:26 AM Phoenix, AZ 85007 . Site Visit Report. Sample Subrecipient Support Letter. Cost-Reimbursable and Fixed Price Subawards Applicable UG section: 200.201 For awards on which UWL is the pass-through entity, subawards are issued on a cost- reimbursable basis. Mike Lauer; News from the Office of Technology Transfer . Determine the readiness of . Monitor programmatic progress and ability of the subrecipient to meet objectives of the subaward Review and approval of subrecipient invoices by PI or designee Monitor each subaward throughout the period of performance and escalate concerns to the school subrecipient monitoring subcommittee Review the OBI subagreements report on a quarterly basis The subrecipient provided additional documentation for the claimed costs, resulting in a reduction of the costs charged by $1,924. C&G will then pay the invoice & it will be reflected in UF's accounting system. instructions. Monitoring Performance During the Life of the Subaward Principal Investigators have the primary responsibility for monitoring subrecipients to ensure the responsible stewardship of funds and performance of the work, including: Authorizing the Subaward, including funding level, period of performance and scope of work Subrecipient means a non-federal entity that receives a subaward from a pass-through entity (e.g., UCI) to carry out part of a federal program; but does not include an individual that is a beneficiary of such program. Subrecipient Monitoring • Subrecipient monitoring is a series of controls, policies, procedures, and best practices put in place to ensure the compliant use of pass-through federal funding to entities performing intellectually significant work for the benefit of an overall project. Author : shart Created Date: 8/22/2018 1:15:27 PM . SPARC provides assistance in the development and submission of proposals and . 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