Budget - Subrecipient Costs - B05.10
Purpose
The purpose of this procedure is to outline the proper handling of subrecipient costs on sponsored projects. For Federal grants OHIO will ensure compliance with OMB 2 CFR §200.330 Subrecipient and contractor determinations, §200.331 Requirements for pass-through entities, and §200.459 Professional service costs.
91̽»¨ will ensure compliance with any restrictions on transactions with foreign individuals or entities as required by federal law, e.g., Executive Order 13224 of September 23, 2001, Blocking Property and Prohibiting Transactions With Persons Who Commit, Threaten To Commit, or Support Terrorism.
Scope
This procedure applies to all sponsored projects subject to OU Policy 19.045 Administering External Grants and Contracts set up as separate accounts in the OHIO Financial Management System (FMS).
Procedure
Proposal Preparation
Subrecipient costs, including their indirect costs, are budgeted in the Subcontracts category. Do not include other types of activities, such as professional services, research subject payments, or vendor agreements in this category. Always use the prescribed budget template to ensure costs are included in the proper categories.
The ORSP Sponsored Programs Manager (SPM) will complete the Subrecipient and Contractor Determinations (see procedure D11 Subaward Management and Monitoring). If the activity is determined to be a professional service instead of a subrecipient, see procedure B05.11 Professional Service Costs for budgeting instructions.
The 91̽»¨ PI will work with their SPM to ensure the following information is provided by the Subrecipient for inclusion in the proposal. The SPM will prepare the Subrecipient Pre-award Checklist to ensure all required information and documents are provided.
Verify through Visual Compliance and/or SAM.gov that the subrecipient listed in the budget is authorized to receive funds (see procedure D11 Subaward Management and Monitoring for more information).
Provide subrecipient organization name and point of contact information for both the Principal Investigator (PI) and the organization.
Provide the Unique Entity Identifier (UEI) or DUNS# and the Employer Identification Number (EIN) of the Subrecipient.
The Subrecipient will provide a Statement of Work (SOW) to be performed under the subaward. The SOW is attached to a Sponsored Research Agreement or a Subcontract/Sub-award Agreement and describes the work to be performed. The SOW should describe the tasks to be performed, the deliverables to be provided to the sponsor and the dates the deliveries are to be made. (Payments may also be associated with the deliverables, particularly if you are working on a fixed-price agreement.) The SOW should also contain a timeline for performance of the project. SOWs that lack specificity in describing the tasks, the deliverables dates, and a measurable timeline for completing tasks and providing the deliverables can often lead to contract disputes because of ambiguities in the agreement and the expectations of the parties. To avoid such disputes, it is important for the parties to be specific in defining tasks, deliverables, timelines, and expectations. If the performance of the project is dependent on any action to be taken by the sponsor, those obligations of the sponsor should also be specifically defined.
Provide the period of performance as indicated in the SOW.
Provide a subrecipient budget prepared using the format and level of detail as required by the sponsoring agency and internal accounting requirements.
Provide a copy of the approved indirect cost (IDC) rate agreement to support IDC listed in the budget.
Subrecipient will provide completed representations and certifications, including financial conflict of interest (FCOI) certifications, if required at the time of proposal submission.
Subrecipient will provide signature of an authorized official of the subrecipient, signifying the collaborator’s commitment to carrying out the project if funded.
Additional institutional forms may be required if the proposal contains foreign subawards, or if the total dollar amount of the subawards requested is more than the amount requested to cover work of the pass-through entity.
The subrecipient will provide the requested subaward information well in advance of the proposal deadline to allow for a review for completeness and its incorporation into the proposal.
Indirect Costs (IDC)
The subrecipient will include IDC using an approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government or, if no such rate exists, either a rate negotiated between the pass-through entity and the subrecipient or the de minimis indirect cost rate as defined in §200.414 indirect (F&A) costs, paragraph (f).
Federal rules allow for 91̽»¨, as the prime institution, to collect indirect costs on the first $25,000 on the life of each subaward to defray the costs of managing the subaward. Any amount over the $25,000 threshold is not assessed indirect costs.
ORSP Budget Review
Based on the information received by the PI/PD at the time of proposal, the SPM will do due diligence to confirm the procurement has been categorized correctly.
Ensure the proposal budget includes a line item for Subrecipient Costs, regardless of the sponsor’s definition of the expenditure. For example, the sponsor may include the procurement of service under supplies or other support, but the grants accounting system always posts these types of expenditures to Subcontracts (EOC #726500). Use the online tools to verify the correct categorization (e.g., subrecipient, professional services, or supplies). Review the sponsor guidelines to ensure allowability of the subaward. Ensure the proper indirect cost has been applied.
Questions
Questions regarding this procedure can be sent to orsp@ohio.edu.
Forms/Templates
Contact your Sponsored Programs Manager for the appropriate budget template
Roles and Responsibilities
OWNER:
CONTRIBUTOR:
APPROVER:
References
D11 Subaward Management and Monitoring
OMB Subrecipient and contractor determinations
OMB Requirements for pass-through entities
OMB Professional service costs