CReATE
Presented by: Marcy Friedle, Grants Compliance Analyst
What Is a Subcontract?
 Assigning to another party some obligation of
an existing contract, for which FSU is still
ultimately responsible
 Used for research collaborations or in cases
where FSU does not have the resources or
expertise to perform the work internally
 FSU generally requires bilateral agreements
(i.e., signed by both parties)
 A purchase order in which subcontractor is
subject only to FSU’s purchasing terms and
conditions may be allowed in limited cases
FSU Subcontract Team
SRS
GRANTS
ADMINISTRATOR
PRINCIPAL INVESTIGATOR
SRS
SUBCONTRACT
COORDINATOR
SRAS SUBCONTRACT
TEAM
Basic Subcontracting Stages
 Pre-Award/Proposal: SRS submits
proposal on behalf of PI
 Award: After prime award received, PI
requests subcontract and works with
SRS Subcontracts Coordinator to issue it
 Post-Award: SRAS pays invoices and
monitors subrecipient for compliance with
A-133 audit requirements
 Close-out
Pre-Award/Proposal Stage
 Ideally, the PI will identify the need for a subcontract at
the proposal stage
 If > 50% of award being subcontracted out, approval
from Vice President for Research required
 Inclusion of subcontract in proposal budget that gets
awarded as proposed should serve as sponsor
approval, unless specific post-award approval or
approval of the actual subcontract document is
required
 SRS will make subrecipient versus vendor
determination in order to determine FSU’s correct
indirect cost base
What is the
difference between
a subrecipient and
a vendor?
Why do we care?
Subrecipient Factors
 Has responsibility for programmatic decision-making
 Uses the funds to play an integral role in the
contracted research program, as opposed to only
providing goods or services to FSU
 Performance is measured against the objectives of
the award
 Has responsibility to comply with all applicable
federal program requirements
Vendor Factors
 Provides the goods or services within its normal
business operations
 Provides similar goods or services to many different
purchasers
 Operates in a competitive environment
 Is responsible ONLY for meeting requirements of
contractual services to FSU, not integral to
programmatic work
Subrecipient vs. Vendor
 This determination will affect the calculation of
indirect costs – only the first $25,000 of a
subcontract with a subrecipient is included in
MTDC base
 The entire amount of a subcontract with a
vendor is included in MTDC base
 Result: Lower indirect costs for subcontracts >
$25,000 when subcontractor is a subrecipient
Pre-Award/Proposal Stage
PI obtains from proposed subcontractor:
 Budget
 Scope of Work
 Commitment Letter
 Other items as required by sponsor (e.g., biographical
sketches)
SRS Grants Compliance Analyst reviews budget for the
following:
 Mathematical accuracy
 Compliance with sponsor’s requirements
 To ensure that proposed subcontractor’s costs have
been included in FSU’s proposal budget correctly (e.g.,
only the first $25,000 of each subcontract with a
subrecipient included in MTDC base)
Award Stage –
PI Responsibilities
PI sends the following items to SRS
Subcontracts Coordinator:
Required:
 Subcontract Request Form
 Subcontractor’s Scope of Work and Budget
 Subcontractor’s Contact Information
 Schedule of Deliverables and Payments
Other:
 Special Certifications (e.g., human subjects, animal
subjects)
 Sponsored Research Exemption Request(s)
 Cost/Price Analysis
Sponsored Research Exemptions
 SRE – Travel
Applicable to subcontracts with out-of-state entities
who are unable to agree to using Florida travel
regulations, or with entities located in Florida who
have their own travel policies
 Available only for awards with non-state funds
 SRE – Competitive Bidding
 Required for any subcontract > $50,000 with a nonuniversity subcontractor who is not named
specifically in the prime award
 Sponsored Research Exemptions are approved by Betty
Southard, Office of Research Legal Counsel
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Cost/Price Analysis
 Required for any subcontract > $6,000
 Used to determine whether the rate being
charged by the subcontractor is fair and
reasonable
 Check that the rate is comparable to the rate
normally charged by the subcontractor or to the
rate of others who do similar work
 PI should complete the Cost and Price Analysis
Worksheet and return to SRS Subcontracts
Coordinator for approval
Cost/Price Analysis, cont.
 Cost Analysis: Element-by-element examination
of estimated costs to determine whether they
are in line with what reasonably economical and
efficient performance should cost
 Use cost analysis in those situations where
price analysis does not yield a fair and
reasonable price
 Price Analysis: Process of deciding if the price
being charged for a product or service is fair
and reasonable without examining specific cost
calculations
Award Stage –
SRS Responsibilities
 SRS Subcontracts Coordinator will work with the PI and proposed
subcontractor to develop the subcontract document
 Information needed includes:
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Subcontractor’s legal name, mailing address, FEID number
Contact information for various subcontractor parties (e.g., PI,
administrative contact, financial contact)
Amount of subcontract (prime award modification may be
required if budget is insufficient)
Subcontract beginning and ending dates (make sure
subcontract dates are within prime award dates)
Subcontract type – cost reimbursable or fixed price (most
subcontracts are cost reimbursable due to inability to define the
product and/or the cost thereof)
Subcontract Document
When drafting subcontract document, SRS
Subcontracts Coordinator confirms the following:
 Agency approval received, if required
 Award budget modification completed, if required
 Sponsored research exemption approval(s) received, if required
 Cost/price analysis received, if required
 Flow-down clauses included, as required by prime award
 Invoicing, technical and financial reporting requirements
(normally, same as requirements of FSU)
 CFDA title and number, award name, name of sponsor, and
applicable compliance requirements, if Federal funds
Subcontract Document, cont.
 SRS Subcontracts Coordinator requests PI’s approval of
final subcontract document
 SRS Subcontracts Coordinator sends final document to
subcontractor, providing any clarification and negotiating
any terms, as needed
 Subcontractor signs and returns document for execution
 Document signed internally and returned to subcontractor
 Subcontract encumbered in OMNI
Post-Award Stage –
SRAS Responsibilities
 Verify that certification on invoice has been signed by
authorized official of subcontractor
 Compare actual costs to subcontractor budget
 Verify completeness and mathematical accuracy of
invoice
 Determine that:
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costs are allowable
sum of current invoice amount and amounts of previous
invoices is within subcontract ceiling
period covered by invoice is within subcontract dates
 Forward invoice to PI for review and approval
 When signed invoice received back from PI, process
invoice for payment and reduce encumbrance
accordingly
Post-Award Stage –
PI Responsibilities
 Review progress reports and other communications to
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ascertain that work is being conducted in a timely manner
Conduct site visit, if warranted
Use other means, as necessary, to provide reasonable
assurance that subrecipient administering funds in
compliance with laws and provisions of subcontract and
that performance goals are being achieved
Review costs to determine appropriateness and
reasonableness in relation to work performed
Sign invoice certifying that work being billed has been
satisfactorily performed
Return invoice to SRAS
Post-Award Stage –
Subcontract Amendments
 PI must contact the SRS Subcontracts
Coordinator to request an amendment to an
existing subcontract
 Reasons for amendments include changes to
any of the following:
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subcontract ending dates (e.g., NCTE)
scope of work
deliverables
funding (increase or decrease)
prime award terms
Close-out Stage –
SRAS Responsibilities
 Confirm subcontractor’s submission of final
invoice
 Ensure final deliverables have been received
prior to approving payment
 Complete disposition of property
 Obtain statement of inventions and any other
required reports per the terms and conditions
of the subcontract
Subrecipient Monitoring
 Annual monitoring for compliance with A-133
audit requirements
 Required for subrecipients who receive
$500,000 or more in Federal awards during
a fiscal year
 SRAS performs various procedures to
ensure that subrecipients have met the audit
requirements in A-133
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Annual Subrecipient Audit Verification
Subrecipient Site Visits/Further Review
Final Report on Monitoring Activities
Contact
Juel Kamke, SRS Subcontracts Coordinator
E-mail:
Phone:
Fax:
Address:
jkamke@fsu.edu
(850) 644-8654
(850) 644-1464
874 Traditions Way, SSB 3rd Floor
Tallahassee, FL 32306-4166
www.research.fsu.edu/contractsgrants/intro.html
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Overview of Procedures
Subrecipient vs. Vendor
Subrecipient Monitoring Policy
Forms
 Request for New Subcontract or Amendment to Existing
Subcontract
 Subcontract Attachments
 Subcontractor Contact Information
 Formats for Scope of Work and Budget
 Schedule of Deliverables and Invoicing
 Cost/Price Analysis Worksheet and Explanation
 Sponsored Research Exemption Request Form
General Policies and Procedures/Procurement of Services
www.research.fsu.edu/contractsgrants/intro.html
Questions?