Subcontracts Procedures and Federal Regulations

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SubcontractsProcedures and Federal Regulations

• Susan Tompkins
• George Walueff

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TOPICS

• Purchase Orders
• Consulting Agreements
• Subcontracts
• Budget impact
• Initiating Subcontracts
• Invoices

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Subcontracts

• Performs substantive programmatic work under a
  grant or contract
• Bears responsibility for programmatic decision
  making and measurable performance requirements
• Subcontractor must adhere to compliance
  requirements of the primary award

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Subcontracts Continued

• Requires prior written permission of the sponsor.
  If in the proposal, award provides permission.
  If need arises for subcontract after award is
  made, required prior approval from the sponsor.
• NOT AN EMPLOYEE OF UD

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Subcontracts

• If, using the above criteria, you determine the
  service required is a subcontract then
• Complete the Provider Category Determination
  Worksheet
• Reviewed by OVPR and Procurement Services

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Purchase Orders

• The procurement of goods or services from an
  organization which provides the goods and
  services to many different purchasers as part of
  its normal business operations within a
  competitive environment
• With federal funds, not subject to same
  requirements as subcontractor
• NOT AN EMPLOYEE OF UD

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Consultants

• NOT AN EMPLOYEE OF UD
• Proven professional or technical competence
• You do not control manner of performance or
  result of service
• Work for hire
• UD retains rights to end product

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Budget Implications

• Subcontracts first 25,000 charged facilities
  and administration costs
• Purchase Orders and Consultants facilities and
  administration costs charged on all dollars
• This information should not be used to determine
  provider category

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Subcontract Initiation by Dept.

• If proposal is funded
• Provide to OVPR
• Provider Category Determination Worksheet
  (formerly OMB questionnaire)
• Contact information
• Statement of Work
• Budget
• Budget justification
• Prepare Purchase Requisition
• With the information above attached

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Subcontract Initiation by OVPR

• Upon receipt of paperwork, OVPR prepares
  subcontract letter with attachments and forwards
  to Subrecipient
• Initiates negotiations with Subrecipient
• Work should not begin until award is issued

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Subcontract Initiation by Procurement

• Procurement Services
• Reviews Provider Category Determination Worksheet
• Obtains additional approvals as required
• lt50,000 Account Administrator, OVPR
• 50,000 - 100,000 also Dean
• gt100,000 - 250,000 also Provost
• gt250,000 also President
• Obtains W-9 for tax id if not provided
• Issues purchase order for payment purposes
• Subrecipient does not get copy

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Invoices

• Received by OVPR
• Forwarded to Principal Investigator for approval
• Invoices should include
• Summary of expenses by category
• Dollar amount
• Date
• Subgrant
• Each invoice must contain the required
  certification (see Attachment 1)
• PI approves invoice and returns to OVPR
• OVPR sends to Procurement Services for payment

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Subcontract Close-out

• Subrecipient required to submit
• Final Technical Report (Interim reports may be
  required by the Principal Investigator, this will
  be specified in the Subcontract)
• Final Invoice (including cumulative costs and
  Cost Share)
• Equipment Report
• Patent/Invention Report
• Subrecipient Release Forms

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USEFUL INFORMATION

• Office of the Vice Provost Office Website, FAQs
• http//www.ovpr.udel.edu/OVPR/do/index?pageId43

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Questions?