• Distinguishing between a Subrecipient, Supplier and Consultant

• See Budgeting for a Subaward/Subcontracts (#12)

All subrecipients that will be receiving federal funds must be registered in System for Award Management (SAM) and have a Unique Entity Identifier (UEI) number.

1. If a proposal is awarded and a subaward was included, SPA’s outgoing Subaward Team is notified by the SPA Award Team.
2. The outgoing Subaward Team will develop a subaward agreement with the organization(s) you intend to collaborate with.
3. The SPA Compliance Analyst will evaluate the subrecipient's ability to maintain complaince with federal statutes, regulations, and the terms and conditions of the subaward. Where a subrecipient is determined to be at risk for non-compliance, for purposes of  subrecipient monitoring, additional terms and conditions will be added to the subaward. These may include more frequent reporting, additional supporting documentation to be submitted with invoices, and restrictions on the use of funds.
4. SPA uses the Federal Demonstration Partnership (FDP) universally approved subaward templates to expedite the process. However, each subaward is prepared to ensure appropriate terms and conditions are delivered to the subrecipient organization.
5. When developing the subaward, SPA will engage with the UVM PI and/or the unit Grant Administrator to review the budget and statement of work for accuracy and look for feedback on reporting requirements and any other programmatic conditions that should be incorporated into the subaward.
6. Upon approval from the UVM PI, the subaward is delivered by email to the subrecipient’s Sponsored Project Administration (or equivalent) for review and signature.

Subrecipient monitoring at the University of Vermont is shared responsibility between Sponsored Project Administration, the Principal Investigator, and the department staff.

Principal Investigator do have the primary responsibility for overseeing performance of the work being conducted by the subrecipient, collecting and reviewing subrecipient performance reports, reviewing and approving subrecipient invoices and ensure any problems with performance are escalated in a timely manner.

For more details see: PI - Subrecipient Monitoring Responsibilities (PDF)

• For details refer to the following procedure and work instructions
  • Outgoing Subaward Invoicing and Payment Procedures (PDF)
  • Subrecepient Invoice Review and Approval for PIs and Project Managers (PDF)
  • Subrecepient Invoice Management for Unit Administrators (PDF)

In summary,

For each invoice, the project manager for the subrecipient agreement will receive an automated email notifying them that there is a subaward invoice needing their approval in the PeopleSoft Financial Module.

The project manager should not approve invoices where the subrecipient is not performing or expenditures are significantly different than budgeted or expected.

Do not approve if the expenditures appear to be unallowable or unreasonable.

If you have questions about a subrecipient’s invoice, contact your post award unit administrator and/or your designated SPA Financial Analyst.

• Changes in the circumstances of a subaward may require and amendment/modification to the agreement.
• If this occurs, the UVM Principal Investigator should contact SPA's outgoing Subaward Specialist to determine what action may be required.
• These changes might include a change in the period of performance, a change in the amount of funding, change in key personnel, or an early termination.

Foreign institutions that will be receiving federal funds as a subrecipient must be registered in U.S federal System for Award Management (SAM) and have a Unique Entity Identifier (UEI) number. SAM registration is free and must be renewed annually. In order to register with SAM, foreign subrecipients must also obtain a NATO Commercial and Governmental Entity (NCAGE) code.

Indirect (F&A) Cost Rates with Foreign Institutions

• Except for NIH (see below), the Uniform Guidance allows foreign subrecipients to use their federal approved negotiated F&A rate, or if they do not have a federal approved F&A rate they may use 10% of modified total direct costs, exclusive of tuition and related fees, direct expenditures for equipment, and subawards in excess of $25,000.

• NIH Indirects Policy:  With the exception of the American University of Beirut and the World Health Organization, which are eligible for full F&A cost reimbursement, F&A costs under grants to foreign and international organizations will be funded at a fixed rate of 8% of modified total direct costs, exclusive of tuition and related fees, direct expenditures for equipment, and subawards in excess of $25,000.

Please always read the sponsor’s guidelines on allowable F&A costs for foreign institutions.

The Federal Funding Accountability and Transparency Act (FFATA) was signed on September 26, 2006. The FFATA legislation requires “Federal Award” spending be made available to the public via a single, searchable website, known as USAspending.gov.

“Federal Award” includes grants, contracts, cooperative agreements, loans, and Prime award recipients first-tier subawards and subcontracts. Under federal contracts (not grants) the term “subcontracts” includes purchase order spending.

FFATA Subaward Reporting System (FSRS)

Federal agencies do not have spending information from the Prime Award recipients lower tier subaward and subcontracts. The Act implements requirements that the Prime Award recipient report this subaward and subcontract spending activity into the FFATA Subaward Reporting System (FSRS).

UVM and FFATA Reporting

When did the FFATA reporting begin?

Grants:

• For new federal grants valued at $25,000 or greater, October 1, 2010

Contracts:

• Phase 1: Contracts valued greater than $20,000,000 (July 1, 2010)
• Phase 2: Contracts valued greater than $550,000 (October 1, 2010)
• Phase 3: Contracts valued greater than $25,000 (March 1, 2011)

Who submits the Subaward Information into the FFATA Subaward Reporting System (FSRS)?

SPA has registered the University of Vermont in the FSRS.gov system and is responsible for timely submission of the subaward data.

• SPA will submit FFATA reports for all campus.
• Purchasing will be responsible to submit FFATA reports concerning applicable purchase orders for all of campus.

Is the FFATA Data available to the Public?

Once the data has been submitted, the public has access to this information through the single, searchable website USASpending.gov.

How much time is allowed to report this sub-award information?

SPA has until the end of the month plus one additional month after the subaward is fully signed, to complete the FFATA reporting requirement.

• For example, if a subaward was made on January 1, SPA has until February 28th to report the subaward information.

What subaward information needs to be reported?

The following are examples of data that must be reported:

• Name of entity receiving the subaward
• Subaward number assigned by prime recipient
• Amount of the subaward
• Funding agency
• NAICS code / CFDA program number
• Award title descriptive of the purpose of the funding action
• Location of the entity
• Place of performance
• Unique identifier (e.g., DUNS) of the entity and its parent; and
• Total compensation and names of top five executives, if applicable.

When must executive compensation be reported?

Prime awardees must report executive compensation information for prime and/or sub-awardees if:

• More than 80%of annual gross revenues are from the Federal government, and those revenues are greater than $25M annually; and
• Compensation information is not already publically available.
• UVM is not required to report total compensation and names of top five executives.

Where can I find additional information concerning FFATA?

• www.fsrs.gov
• www.USASpending.gov

For subaward learneing and education opportunities, please visit SPA EDU.

If your department would like a workshop on outgoing Subawards, please email Sally Roberts, SPA's outgoing Subaward Specialist.

If you have any questions about outgoing subawards, please contact SPA's outgoing Subaward Specialist.