Subgrants & Subcontracts Training
Nov 2014
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Drafting, execution, and termination of
outgoing subgrants and subcontracts
Purchase order creation, management, and
termination
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A subgrant or subcontract is necessary when:
◦ The site will perform work which satisfies a direct
objective or deliverable of the Prime Award
◦ The site will be responsible for programmatic
decisions or design related to the project/study under
the Prime Award
◦ The site will be held accountable to the compliance
regulations of the Prime Award (COI, IP, etc) or may
seek to publish/co author the study results
◦ The site will use the Prime Award funds to carry out
its own programmatic work
◦ The site provides cost sharing or has key personnel
mentioned in the NGA
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Service/Vendor Agreement (drafted by Purchasing, PO set
up by dept):
◦ If the site is providing standard services (those in the normal
operations and markets to a variety of customers)
◦ If the site has not/will not provide significant contributions to the
design/conduct of the project
◦ If the site is not responsible for the project results
◦ If the site performs work that involves routine or repeated
activities
◦ If the site will not seek to publish or co-author based on the
academic standards such as the ICJME standards
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Storage (drug, supplies, etc.)
Website design & management for a clinical trial.
KKI Kirby Center Agreements
Draft Examples: http://ssc.jhmi.edu/supplychain/forms/index.html
Data Use Agreement
Complex Material Transfer Agreement
Collaboration Agreement
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Subaward Agreements under
◦ Federal and state grants/contracts
◦ Foundation grants
◦ Commercial contracts
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Subaward Agreements with funding from
multiple sources
◦ Please try to make us aware of all the sources of funding
(commercial and non-commercial) for the Subaward
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Agreements under internal JHU awards (800
IOs)
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INTERNAL
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NTAP – Neurofibromatosis Therapeutic Acceleration
Program
ABTC – Adult Brain Tumor Consortium
PACKARD – The Robert Packard Center for ALS
Research
OTHER
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TBCRC – Translational Breast Cancer Consortium
CRN – Clinical Research Network (AAHSRI, GBMC,
INOVA, PRMC, RHMC)
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SOM ORA Subawards Process Chart…
Subaward paperwork
ORASUBCONTRACTS@jhmi.edu receives notice of
prime award set up with Subawards under it
ORASUBCONTRACTS emails COEUS PD dept contact
to request prime award specific
Department sends back ALL requested paperwork
and file is assigned to Subs Team Member (STM)
Subaward Preparation
STM evaluates paperwork and information, STM
requests additional information from dept if
necessary and drafts agreement
STM requests vendor number (if necessary), 96 IO,
and Shopping Cart for Purchase Order
STM submits draft for internal review and corrects
draft accordingly
Subaward Negotiation
STM sends draft to subsite for review and
negotiation
Subsite returns revisions for STM approval
STM (supervisor) approves/rejects revisions, emails
site with explanation/clean draft (repeat until draft
is satisfactory to both parties)
Subaward Execution
STM receives signed copy from subsite (PE) and
adds PO number to original agreements or money
to PO for modification agreements
STM submits PE to supervisor for signature;
supervisor reviews, signs and dates agreement (FE)
ORASUBCONTRACTS sends FE to dept & subsite
separately with invoice instructions and closes file
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For originals:
 A Subaward Determination Form
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This is completed and signed by the JHU PI, and uploaded into COEUS during the
proposal phase. The outgoing subs team will sign for ORA and keep the form in
the Subaward file
A Subaward Information Sheet
A budget for the subsite
A statement of work for the subsite
IRB/IACUC approval for the subsite (if applicable)
Wire transfer agreements for subsites in foreign countries
Conflict of Interest Documentation (Federal Prime)
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if site is not in the FDP Clearinghouse
http://sites.nationalacademies.org/PGA/fdp/PGA_070596
 And for new sites… Questionnaire, DUNS #, SAM registration, W9
(domestic), W8 (foreign, using domestic bank)
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For modifications:
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A Subaward Information Sheet
A budget for the subsite
A statement of work (but only if it has changed significantly)
Updated IRB/IACUC approval (if applicable)
Conflict of Interest Documentation (Federal Prime)
 if site is not in the FDP Clearinghouse
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ORASUBCONTRACTS@jhmi.edu
for processing and assignment to a Subawards Team Member
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Subawards Specialists draft subs under Federal Grants
When the prime award is a federal contract, a commercial contract, or an
award from a foundation, it will be handled by:
◦ Melody:
 Original subcontracts under federal and all commercial contracts
 CRN SSA’s, NTAP, TBCRC, internal accounts
◦ Michelle:
 Subs under foundation awards
 Modifications of subcontracts under federal contracts
 ABTC
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JHU contact information
 The “Financial Contact” is the person who processes invoices and
goods receipts
 The “Study Contact” is the person who can answer scientific questions
about the protocol.
Most recent subsite contact information
 In most cases, the contact should be in the Research Administration
office at the subsite.
 Verify that it is current each year an Information Sheet is submitted.
SAP grant #, COEUS IPN #, Prime award/contract IO #, PI’s cost center #
Sponsor grant/contract # (JHU is only the “sponsor” under 800 act's)
Deliverables and due dates/time-lines for new/revised SOW’s
Whether animal and/or human subjects research is going to be
conducted at the subsite.
Budget Period for the sub & amount to pay the subsite (PO amount)
Information related to the Study for Clinical Trials
Information related to Transfer of drug, equipment or materials.
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Cost Reimbursement budgets for subs under
Federal grants should include:
 Names of personnel
 Breakdown of costs for equipment, supplies, and “other
expenses”
 Explanation of travel costs
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Fixed Fee budgets: if the site is going to be paid
for each patient it accrues, or for each sample it
obtains, etc., the budget
indicate the
number of patients/samples and the amount that
will be paid for each one.
Consider whether the costs are allowed under the
terms of the award/contract.
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Alternately known as a “work scope”, the SOW is a short
paragraph describing what the Subsite is doing. The SOW
should NOT be a summary of the whole grant.
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The SOW should also state what the subsite is going to
provide to JHU in exchange for being paid (“deliverables”).
◦ Examples include patient data from clinical trials, blood samples,
tissue samples, assays, scans, and analysis of samples, or even
reports/publications and conference calls to discuss results.
Deliverables can be tied to payment (Fixed fee budgets: the site
will be paid $10,000 for every five patients it enrolls)
SOW should be understandable to non-scientists.
The SOW is used in a dispute to determine whether the site is
performing in accordance with the agreement, so be clear and
specific.
The Deliverables table will be part of the SOW and subaward
and should include concrete due dates/time lines
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It is up to the Subsite’s IRB/IACUC to determine
whether human subjects and/or vertebrate
animals research is being conducted.
ORA does NOT need the Subsite IRB approval to
send the Agreement, but we must have it to
fully-execute the Agreement.
KKI and the CRN site Study Team Members
should be included as part of the JHU IRB
approval prior to submission of paperwork to
ORASUBS
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Contains bank account and payment
information for the Subsite.
 Is attached to the Subaward as an
exhibit
 Must be copied onto Subsite
letterhead
 New foreign vendors also require a W8
if the site is using a domestic bank
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NOTE: new domestic vendors may also require a W9 so that a
vendor number can be requested for the PO
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Under Federal grants and contracts, all
Subrecipients should be registered in the
System for Award Management (“SAM”), and
must have a DUNS number
◦ SAM website: https://sam.gov
◦ DUNS number requests: http://fedgov/dnd.com/webform
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High Risk Subrecipient Monitoring:
◦ ORASUBS will identify sites that need to complete a Subrecipient
Questionnaire
◦ The Dept will send the Welcome Packet and Questionnaire to the
identified sites and return it to ORASUBS
◦ ORA rates the sites and notifies the dept and Internal Audits who
confirms the rating and performs subsite audits
◦ High Risk Subrecipients must submit invoices on template included as
exhibit to the cost reimbursement Sub Agreement.
◦ The JHU dept must complete additional invoice audits per the new risk
management regulations which took effect on 7/1/14.
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As of 8/24/12: Subsites are required to submit COI
information at the time of JHU application to the JHU
Grants Associates if they are not registered in the FDP
Clearinghouse.
2 Options:
◦ Complete, and certify best ability at time of JHU application
◦ Opt to complete certification at time of Subagreement award
Subs team will choose appropriate COI language for
the Agreement
If SCF was not completed at time of JHU application
and the site is not registered in the FDP
Clearinghouse, Subs team will request that the dept
get an SFI from the Subsite prior to submission of
Subaward documents to ORASUBCONTRACTS.
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Under Federal subs…(MTDC)
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For subs under federal grants and contracts, JHU takes additional IDC on the
first $25K of the subcontract budget.
For every subaward agreement drafted JHU IDC is requested
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Ex: Proj A, Core, Proj B under P50 – all to UMB, different PI’s = multiple 96s and POs
and agreements = JHU additional IDC one time.
Under non-Federal agreements…(TDC)
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Generally, under foundation awards and commercial contracts, the same IDC
rate is applied to both the JHU and the subsite budget.
For foundation awards, it must be determined if the awarded IDC is shared
with the subsite or if the subsite TC is part of the JHU TDC.
If the IDC is shared JHU does not take additional IDC against the 96. If the
subsite total costs are part of the JHU TDC, JHU takes the additional IDC %
allowed by the Sponsor against the entire Subsite amount, not just the first
25K.
When setting up 96 numbers for subs under commercial agreements with
fixed fee budgets, JHU does NOT charge any additional IDC against the 96#;
o For commercial clinical trials a “receipt tax” is charged at the time the money is paid to
JHU.
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When setting up 96 numbers for subs under commercial agreements with cost
reimbursement budgets, JHU does charge additional IDC against the 96# per
the prime award budget/terms;
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The 96 number simply refers to the SAP account
number for the sub.
A 96 number is a “child” of a “parent” Internal Order
number (IO), which will always start with “900”.
The 96 # will be set up with the sub amount, plus
whatever IDC JHU is entitled to take.
o Except in the case of commercial clinical trials and most
foundation awards.
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Generally speaking, the IDC rate for the 96 # must
match the IDC rate for the IO # it is based upon,
although there may be some (limited) exceptions.
After the first year of the Subaward, the departments
are responsible for distributing money to the 96 #.
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JHU has negotiated a number of IDC rates with the
NIH. Determining which rate applies to the 96
number depends in part upon whether the work for
the Prime Award (at JHU) is conducted “on- campus”
or “off-campus.”
“On-campus”- means that the University is paying for
the space where the work is conducted.
“Off-campus”- means that the University is NOT
paying for the space where the work is conducted.
Note that the decision about which rate to use for the
96 number is made based on the work being
performed at JHU. It has nothing to do with the
location of the subsite.
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ORA’s default position on carry over: subs follow
the terms of the prime grant or contract
However, even in cases where the prime
grant/contract allows for automatic carryover, the
department and PI may request ORA to set up subs
so that the subsite must obtain authorization to
carry over any funding.
In order for funding to be carried over under Federal
funding, the balance should be reported on the
Financial Status Report as an “unliquidated
obligation.”
If the prime award is from a foundation, the
carryover process should comply with award
guidelines about how much money can be carried
over, etc.
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Carryover modifications are always necessary
when the prime grant or contract requires
JHU to obtain authorization for carrying over
prime grant/contract funding.
◦ Almost always necessary for P and U awards
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A carryover modification authorizes the
subsite to carryover funding from one
subgrant/contract budget period to another.
Carryover modifications must specify the
amount of funding being carried over, but do
not need to include a whole new budget.
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The Federal Funding Accountability and
Transparency Act (“FFATA”) was a 2006 federal
law intended to hold the government accountable
for its spending by allowing individuals to track
information on federal grants and contracts on a
searchable website (www.USASpending.gov)
Under FFATA, recipients of federal grants and
contracts must report Subaward and Subcontract
spending.
 The SOM Subawards Coordinator will handle the reporting
 Subsites will be asked to provide certain information to
facilitate the reporting process.
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Intellectual
Property
Payment
Information
Indemnification
Technical
and
Financial
Reporting
What’s in a Sub Agreement??
Confidentiality
Termination
Adverse
Event
Reporting
Certifications to the
Grantor or
Sponsor
Contact
Information
Period of
Performance
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Managing Purchase Orders
What the Subs group does in relation to purchase orders:
Creation:
P.O. is created when the contract is created.
Modification:
Time and/or money added (or removed) when sub is
modified.
Close-out:
P.O. is closed when project period of grant/contract ends,
or sub is terminated early. If money is left on 96#, the close
out process will unencumber it.
**Do NOT have Purchasing or SAP help do these things!**
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 ORA closes the Purchase Order once the final invoice is approved,
submitted to AP, confirmed and paid. If the period of
performance for the subaward has expired, the department sends
the ORA Subawards Team (ORASUBCONTRACTS@jhmi.edu) and
email with the PO number indicating to close it. PLEASE DO NOT
EMAIL PURCHASING/AP/SPSS/SAP/PO MAINTENANCE FIRST!
 The Subawards Team does not move money off of or unencumber
money from the 96. If this does not automatically happen when
the PO closes, please reach out to Purchasing@jhu.edu or
SAPHelp@jhu.edu for more help.
 If there were expenses on a P.O. before the January 2007
conversion to SAP, they will show up on the 642400 general
ledger number, which links to the IO number, NOT to the 96
number. Thus, if we are closing a P.O., and there is money on
642400, the Real Time Grant Report will still show that there is an
encumbrance on the IO number. ORA cannot fix this problem.
For help, contact the SAP help line and/or Purchasing.
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There are several situations where a Subaward might need to be closed out before the
period of performance expires.
If the period of performance has not expired AND a final invoice has been paid:
◦ The department should send an infosheet to ORASUBCONTRACTS
◦ On the infosheet the period of performance should start on the date of their last
agreement and end on the final invoiceable date
◦ On the infosheet the amount should be the total amount paid for that period of
performance
◦ ORA will send the site a termination modification AND close out the PO/SC once the
mod is fully executed
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The period of performance has expired AND a final invoice has not been sent:
◦ The department should send an infosheet to ORASUBCONTRACTS
◦ On the infosheet the period of performance should start on the date of their last
agreement and end on the last date the sub PI completed work for JHU
◦ ORA will send the site a termination modification
◦ The department should email ORASUBCONTRACTS when the final invoice is paid
◦ ORA will close out the PO/SC at that time
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If the subsite PI is moving to another subsite and will
still conduct work for JHU under the project
◦ The department should request paperwork from
ORASUBCONTRACTS for a new subsite
◦ The department should complete and return the paperwork to
ORASUBCONTRACTS
◦ ORA will draft and submit the new sub AND create new 96/PO
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If the subsite is appointing another sub-PI to do the
work at their Institution
◦ The department should send an infosheet to
ORASUBCONTRACTS with the new PI’s information on it and a
new budget for that PI for the remaining portion of the current
grant year
◦ ORA will modify the current agreement with the subsite
◦ The existing 96/PO will continue to be used
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What the Departments do in
relation to purchase orders:
• Process and pay invoices
• Complete goods receipts
• Ensure consistency with Real Time
Grant Report and BW reports
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Per the terms of our contracts, subsites should send invoices to the
department financial contact on the sub information sheet.
If ORA receives an invoice erroneously, it will be forwarded to the
Financial Contact for the sub.
Confirm with the PI that the work has been performed and that any
necessary reports have been submitted. PI should be aware of
payments.
Certification for Payment should be completed and signed by PI
Departmental contact sends invoice and Certification to Accounts
Payable via e-mail. Make sure to keep a copy. The e-mail should
indicate if the invoice should be split between lines on the purchase
order and how much to put on each line.
For Fixed Fee/Per Patient budgets, dept should send an email to
ORASUBS asking for money to be added to the PO BEFORE submission of
the invoice to AP.
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Name of the subrecipient
JHU purchase order number
Date of the invoice
Invoice number and project title
Period of performance covered by the invoice
Breakdown of costs in accordance with expenditure
categories
Current period costs and cumulative project costs
Cost sharing (if applicable)
Program income (if generated)
Contact person for invoice questions
Certification as to the truth and accuracy of the invoice
Shouldn’t overlap with previous invoice and should NEVER
exceed the termination date.
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 Review for standard invoice elements as required by current policy
(e.g., cumulative costs, certification etc.)
 Expense in line with budget category amounts
 Amounts aren’t round dollars solely based on a percentage of budget
 Previous expense + Current expense = Cumulative expense for each
budget category
 Column totals equal the amount of individual column amounts in total
 Fringe cost are in line with salary expense for the agreed upon fringe
rate
 Facilities and Administrative (F&A) costs are in line with applicable
costs for the agreed upon F&A rate
 Period of performance invoiced is not in advance of the current
calendar date unless immediate cash needs are being met. If so, cash
balances and interest must be tracked and reconciled before
additional payments can be made.
 Be sure that cumulative amount invoiced is less than or equal to total
amount of the subaward/subcontract.
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Certification for Payment and Performance must be
completed for all invoices
Confirm with the PI that the work has been performed and
that any necessary reports have been submitted. PI should be
aware of payments.
Approval by both Financial Analyst and Principal Investigator
is required
Form must be included with invoice in order to process
payment in SAP
Form is emailed to JHU PI with every fully executed agreement
and is located on JHU Finance website.
https://apps.finance.jhu.edu/policy_procedures/policy/sub/cert_pymt_perf.docx
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High-risk subrecipients will be required to submit general ledger
summary and detailed financial reports along with all invoices
Departmental personnel will be responsible for completing a
summary comparison of the invoice to the financial reports
Every six months, departmental personnel will complete a more
detailed review of a subrecipient financial report supporting one
invoice, including obtaining supporting documentation for a
selection of charges
The Certification for Payment and Performance form has been
revised to evidence these reviews
◦ A summary review is required to be performed and must be
documented on the Certification for Payment and Performance
◦ Date of last detailed review must also be documented
Problems identified with billings must be resolved and the resolution
documented
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How to handle discrepancies identified during invoice
reviews:
◦ Must be resolved prior to payment
◦ Partial payments of invoices are allowable (e.g., withholding
questioned costs)
◦ Significant discrepancies may indicate the need for a 100%
desk audit of the specific invoice or all invoices depending
on the nature of the concern
◦ Resolutions must be formally documented on the invoice or
payment certification form
◦ At discretion of departments, results may dictate future
invoicing requirements (e.g., submission of timesheets with
every invoice)
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Goods Receipts (GR) are confirmations that goods or services have
been received. A GR must be completed for each invoice that is
submitted to AP for payment.
Goods Receipts facilitate the “Three Way Match”, which means that
the P.O., the Goods Receipt, and the vendor invoice all show the
same price and quantity.
 A GR request is sent to the ORA STM’s ECC inboxes, who forwards it to the
ECC inbox of the appropriate departmental contact.
 The Subawards Manager is able to reverse GR’s that were done through the
ECC inbox. The dept contact is able to reverse GR’s that were done
through Central Receiving.
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Two methods for completing goods receipts (see handout). (Central
Receiving SAP Role: ZESC_SC_RCV_CNT_All)
SAP manuals available at: http://ssc.jhmi.edu/supplychain/training
GRs can be reversed by the dept if it was completed via Central
Receiving or by the Subawards Manager if not
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Complicating factors in completing a sub:
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Please do NOT:
◦ Subsite wants indemnification from sponsor
◦ Subsite has not obtained IRB approval
◦ Sponsor has to approve something- like the replacement of
a project director.
◦ Payment/Purchase Order issues
◦ Make payments to subsites via online check requests
◦ Provide subsites with purchase order numbers before
original contracts are fully-executed.
◦ Create goods receipts before the invoice has been posted in
SAP.
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Generally speaking, the Subs group
cannot resolve BW and Real Time
Grant Report issues (incorrect
encumbrances, etc.).
 We only close the PO/SC, and reverse
GRs.
 For encumbrance issues contact
Purchasing, PO Maintenance, or SPSS
accordingly.
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If you have questions about what you need to
submit or something the subsite is asking
for, please call or e-mail us.
Melody Snow, M.H.S.
Subawards Manager
443-287-0701
msnow1@jhmi.edu
Michelle Sloan, M.H.A.
Subawards Associate
410-614-1716
msloan7@jhmi.edu
Rhanota Edwards, M.S.
Subawards Specialist
410-502-7349
redwar20@jhmi.edu
Jessica Spielman, B.S.
Subawards Specialist
410-502-0776
jspielman@jhmi.edu
Subawards Specialist
410-502-0558
pstuart1@jhmi.edu
Paul Stuart, B.S.
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