Sponsored Programs at Penn Proposal Budget Preparation, Budgeting Using PennERA and Routing & Approval 1 REVISED February 2014 The Office of Research Services The Office of Research Support Services Where Do You Start? • Gather the Facts – Talk to the Principal Investigator (PI) • What is the Scope of Work? • Who is the Sponsor? • Where will the work be performed? • Collaborators? • Consultants? 2 REVISED February 2014 The Office of Research Services The Office of Research Support Services Sponsor Guidelines • • • • • • Instructions and Contractual Terms Requests for Proposal/Quote (RFP/RFQ) Requests for Application (RFA) Funding Opportunity Announcements (FOAs) “Unsolicited” Applications Send sponsor guidelines, instructions, contractual terms, etc., to Research Services 3 REVISED February 2014 The Office of Research Services The Office of Research Support Services Cover Page • PI Name • Title • Name of Grantee – Trustees of the University of Pennsylvania • Period of Performance • Amount Requested • Required Signatures 4 REVISED February 2014 The Office of Research Services The Office of Research Support Services RFQuotation RFApplication RFProposal • Government generates scope of work via Notices/Program Announcements. • You respond with how you will accomplish, budget and time frame. • Contract is usual award document for RFP/RFQ while a grant/cooperative agreement is usual award document for RFA. 5 REVISED February 2014 The Office of Research Services The Office of Research Support Services Budget preparation is a collaborative effort! • Principal Investigator: – Should work with the Grants Manager to develop the budget. – Designates others who might have input, e.g., lab manager, research coordinator. 6 REVISED February 2014 The Office of Research Services The Office of Research Support Services Reasons for carefully preparing the budget • Reduces the possibility of significant budget cuts by the sponsor. • Aids post-award management. • Aids the department in budget planning. • Significant budget changes are interpreted by sponsors as a change in scope! 7 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget • Costs requested in proposal budget must: – Be Allowable (Factors used in determining) • Allocable • Reasonable • Consistently Estimated – Directly benefit the proposed project Costs must be necessary for the performance of the award (OMB Circular A-21); SPP #2108, #2110, #2138 REVISED February 2014 8 The Office of Research Services The Office of Research Support Services Regulatory guidance • CAS 501 (app. OMB A21, 48 CFR 9905.501) – “The purpose of this standard is to ensure that each educational institution's practices used in estimating costs for a proposal are consistent with cost accounting practices used by the educational institution in accumulating and reporting costs.” 9 REVISED February 2014 The Office of Research Services The Office of Research Support Services Other considerations • Sponsor guidelines and limitations – – – – Salary caps F&A limitations Direct cost or total cost limits Expense category exclusions • Recover F&A as direct costs from nongovernmental sponsors – SPP #2138 Direct Cost Expenditures for NonGovernmental Agencies • May be School-specific rules 10 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (Salary) • Salary requests are expressed as % effort or person months • Plan realistically – Determine the percent of effort for all personnel needed to conduct the project – Downward adjustments of effort may need sponsor approval • Percent of effort=Percent of salary requested – Cost sharing is discouraged – Avoid hourly rates • Cannot usually charge clerical salaries or administrative costs directly 11 REVISED February 2014 The Office of Research Services The Office of Research Support Services Allowability of clerical and/or administrative staff expense • Generally part of F&A costs. • Possible exceptions (see OMB A21, Exhibit C): – Large, complex programs (e.g., Center grants). – Epidemiological studies, clinical trials. – Scheduling seminars/conferences attended by large numbers of participants. – Individual projects requiring project-specific tasks such as database management, human and animal protocols, etc. 12 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (Benefits) • Fringe Benefits are charged as a % of Salary • As of 06/21/13, rates on federally sponsored projects: – Full-time employees – 31.8% – Part-time employees - 9.7% • For non-Federal sponsors, add Spouse and Dependent Tuition Benefit (2.2% ) for fulltime employees • Current F&A and benefits rates 13 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (Equipment) • Definition – “Equipment” costs $5,000 or more per item, and has a useful life of more than 1 year – Includes computer software that meets this definition (capitalized computer software). • Accounting Policy #1106.0 • Justification – Why is this item necessary to support the science? – When is it necessary? • Availability – Is the equipment available elsewhere in the University? • Competitive Bid Requirement 14 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (Office Supplies) • Generally not treated as direct costs. • Can be allowable if specifically related to the project. For example: – Specific aim of the project is to create a manual or other instructional media. – Extensive human subjects data accumulation, questionnaires, etc., is required. • Must be necessary for conduct of project – OMB Circular A-21, Exhibit C 15 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (Travel) • Usually restricted to employees • Domestic • Foreign – Fly America Act if Federal $$ – May require prior approval even if in budget 16 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (Patient Care) • Defined in rate agreement: “…hospitalization and other fees associated with patient care whether the services are obtained from an owned, related, or thirdparty hospital or other medical facility…” • Excluded from MTDC base and F&A calculations. 17 REVISED February 2014 The Office of Research Services The Office of Research Support Services What is not included in patient care? • Subject reimbursement and travel. • Costs of ancillary tests performed outside the hospital on a fee-for-service basis. • Costs accumulated in service centers at Penn, such as in Radiology for research patient care. • Consulting physician fees. • All of the above are “other” or “consultant” expense. 18 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (Subcontracts) • • • • Budget, including F&A costs Copy of F&A rate agreement Statement of Work (SOW) Cover page/Letter of Intent with Authorized Signature • Reps/Certs required by sponsor 19 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (Consultants) • Penn staff usually cannot be included in this category – If applicable, must coordinate payment through Penn Payroll Office. • Consultant’s letter of intent and cost – All costs related to the consultant including travel are usually accumulated in this category. • Statement of Work – Consortium agreements typically used if consultants are identified as Key Personnel. 20 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (Other Direct Costs) • • • • • • • • Service Center charges Tuition and Fees (Research Projects) Post Doctoral Health Insurance Publication Costs Protocol Review fees, when appropriate Rent, when appropriate, but excluded from MTDC. Animal per diem. Subject compensation and travel SPP #2110 Federal Direct Cost Expenditures; SPP #2138 Direct Costs Expenditures for Non-Government Organizations 21 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (F&A Costs) • F&A = Overhead = Indirect Costs – Pays for many costs that cannot be allocated to a specific project, i.e. utilities, administrative payroll and other support services, etc. • The “Colleges and Universities Rate Agreement” contains the federally negotiated F&A rates • F&A usually expressed as a % of a base • Modified Total Direct Cost Base (MTDC) – Excludes equipment, patient care costs, student tuition, and fees, alterations and renovations, rental of off-site facilities and the portion of each subcontract in excess of $25,000 • Check sponsor guidelines for appropriate base 22 REVISED February 2014 The Office of Research Services The Office of Research Support Services Preparing the Budget (F&A Costs) • Which rate to use? – – – – Research rates (on- and off-campus) [60% & 26%] Certain DOD Contracts [62%] Instruction [57%] Other Sponsored Activities (on- and off-campus) [36% & 26%] • Examples: health or community service projects, seminars, conferences, exhibitions, lecture programs – Clinical Trials [28% Total Direct Costs (TDC)] – Corporate Contracts [62%] • Current agreement 23 REVISED February 2014 The Office of Research Services The Office of Research Support Services When is the offsite rate applicable? • Use this rate whenever activity will occur for 3 months (or 25%) or more at a facility not owned by the University. – Consider preparing a split-rate budget when appropriate. • Remember that rent can be a direct charge when using the off-site rate. – Rent is excluded from MTDC and F&A calculations. 24 REVISED February 2014 The Office of Research Services The Office of Research Support Services Don’t overlook • Are there humans involved? – Subject compensation and travel? – Related patient care costs? – Equate costs proposed to research plan, especially with the consents. • Are there animals involved? – Prepare detail cost estimate: include shipping and box charges. – Animal per diem? – Equate costs proposed to research plan. 25 REVISED February 2014 The Office of Research Services The Office of Research Support Services …and more • Are there large pieces of equipment? – Installation and set-up included? – Maintenance contracts? – Space available or renovation costs included? • Provide a quote. • Are there pre- and or post-docs? – Tuition included? • Excluded from MTDC and F&A. – Health insurance costs listed? • Not excluded from MTDC. 26 REVISED February 2014 The Office of Research Services The Office of Research Support Services Budget Justification • Each line item usually requires specific justification. • Unusual or extraordinary expenses such as equipment, clerical salaries and administrative expenses, may require additional justification. • Check sponsor guidelines for requirements. 27 REVISED February 2014 The Office of Research Services The Office of Research Support Services Other Considerations • Specific Sponsor Requirements – NIH modular: ≤$250,000/year – Many non-Federal sponsors may not allow PI salary, benefits, travel, etc. • Penn Participation Agreement 28 REVISED February 2014 The Office of Research Services The Office of Research Support Services Terms & Conditions • Terms and Conditions – Must be consistent with University mission of research, education and service – No bars on publication – University owns and controls intellectual property – Federal regulations appropriate to educational institutions are used 29 REVISED February 2014 The Office of Research Services The Office of Research Support Services Budgeting Using PennERA Proposal Development (PD) 30 REVISED February 2014 The Office of Research Services The Office of Research Support Services Budgeting Using PennERA PD • Type of budget is automatically determined by PD during proposal setup. 31 REVISED February 2014 The Office of Research Services The Office of Research Support Services Budgeting Using PennERA PD • Type of budget is automatically determined by PD during proposal setup. • Proposal creator answers questions so that PD can select the correct configuration. 32 REVISED February 2014 The Office of Research Services The Office of Research Support Services Sample Budget Configurations Typical setup – detail or simplified entry, S2S or generic records. Modified for NIH modular budget – detail or simplified entry, only S2S. Noncompeting records or S2S not requiring a detail budget. 33 REVISED February 2014 The Office of Research Services The Office of Research Support Services Budgeting Using PennERA PD • Two budget entry methods – Simplified •Minimal data entry •Use if not a Federal systemto-system (S2S) requiring a detail budget 34 REVISED February 2014 The Office of Research Services The Office of Research Support Services Budgeting Using PennERA PD • Two budget entry methods – Detail •As required by Federal sponsor’s instructions •Can be used in any PD record 35 REVISED February 2014 The Office of Research Services The Office of Research Support Services • Detail – Personnel Expense 36 REVISED February 2014 The Office of Research Services The Office of Research Support Services • Detail – Personnel Detail Entry 37 REVISED February 2014 The Office of Research Services The Office of Research Support Services • Detail – Non-Personnel Expense 38 REVISED February 2014 The Office of Research Services The Office of Research Support Services • Detail – Non-Personnel Detail Entry 39 REVISED February 2014 The Office of Research Services The Office of Research Support Services • Detail – Subcontract Expense 40 REVISED February 2014 The Office of Research Services The Office of Research Support Services Budgeting Using PennERA PD • Complete other sections: – F&A •Many proposal records calculate F&A automatically •If manual entry is used, reset to autocalculation if editing budget expense data entry 41 REVISED February 2014 The Office of Research Services The Office of Research Support Services Budgeting Using PennERA PD • Complete other sections: – Cost Sharing •Observe Penn’s cost-sharing policies •Complete cost-sharing form – Upload Budget Justification 42 REVISED February 2014 The Office of Research Services The Office of Research Support Services Routing & Submission 43 REVISED February 2014 The Office of Research Services The Office of Research Support Services PI and BA Submit Proposal • PI and Business Administrator (BA) have completed all components in PD • Participation Agreement signed and filed in department • Upload internal documents (e.g., subaccount worksheet) • PI completes certification • BA completes e-transmittal form • Record submitted to routing path for internal review 44 REVISED February 2014 The Office of Research Services The Office of Research Support Services • What’s a routing path? …and… 45 REVISED February 2014 The Office of Research Services The Office of Research Support Services • What’s a routing path? …and final step… • Approvers notified by e-mail message when previous reviewer approves the proposal. • Only one approval is required per step. 46 REVISED February 2014 The Office of Research Services The Office of Research Support Services Research Services Review • Review e-Transmittal Form & PI certification for Accuracy & Completeness • Regulatory Issues • Determine Type of Award • F&A Cost Review • Conflict of Interest • Cost Sharing • Terms & Conditions if applicable • Check for electronic submission validation issues 47 REVISED February 2014 The Office of Research Services The Office of Research Support Services Purpose of e-Transmittal • The Transmittal Form – Internal Form • Does not get submitted to sponsor – Uses • Departments, make commitments & determine that project is within total program and academic objectives of department • Deans, determine that project is consistent with the total program objectives of the school and that commitments for project (including any cost sharing/matching funds) are acceptable • Research Services uses it to create funds; accuracy matters 48 REVISED February 2014 The Office of Research Services The Office of Research Support Services Proposal Routing and Submission • Approvals – If project includes faculty from multiple schools/departments • Plan for additional time to secure appropriate approvals – If project includes participation from another institution • Information from the other institution must also be obtained and presented in the application • Plan for delays – Electronic proposal submission issues – Administrative support assisting with multiple grant applications from multiple PI’s – Broken copiers, scanners 49 REVISED February 2014 The Office of Research Services The Office of Research Support Services Proposal Routing and Submission • Applications requiring additional information (financial reports) require more time • Responses to RFP’s – Contractual terms sent to Research Services as soon as possible – Policy requires 5 days • PI’s transferring from another institution should begin the transfer process as soon as they have accepted a position at Penn • Observe individual School deadlines 50 REVISED February 2014 The Office of Research Services The Office of Research Support Services Regulatory Issues • IACUC • IRB • PI Submits Protocol electronically for Human Subject research using the HS-ERA system and for Animals using ARIES. 51 REVISED February 2014 The Office of Research Services The Office of Research Support Services Office of Regulatory Affairs • Administers – Institutional Review Board (IRB) – Institutional Animal Care and Use Committee (IACUC) • Provides Research Services with approval status for all protocols 52 REVISED February 2014 The Office of Research Services The Office of Research Support Services Institutional Review Board • Protects the rights and welfare of human research subjects • Authorized to approve, require modifications in, or disapprove all research activities involving human subjects 53 REVISED February 2014 The Office of Research Services The Office of Research Support Services Human Subjects Approval Requirements & Timelines • Approval of a human subject protocol for a new application is not required at time of submission – Unless mandated by sponsor – Approval can be “Just-in-Time” for NIH • Human subject protocol approval and appropriate education certification – Required to be in place prior to the awarding of a new project 54 REVISED February 2014 The Office of Research Services The Office of Research Support Services Human Subjects Approval Requirements & Timelines (cont.) • For non-competing continuations the approval date must not be earlier than one year before the start date for which the progress report is submitted – If the protocol approval date does not meet this criteria the non-competing application will be delayed 55 REVISED February 2014 The Office of Research Services The Office of Research Support Services Institutional Animal Care and Use Committee (IACUC) • Reviews and approves the care and use of animals in research 56 REVISED February 2014 The Office of Research Services The Office of Research Support Services Use of Animals Approval Requirements & Timelines • Approval of an animal subject protocol for a new application is not required at time of submission – Unless mandated by sponsor – Approval can be granted “Just-in-Time” for NIH • Non-competing continuation applications must have a valid approval date at the time of submission 57 REVISED February 2014 The Office of Research Services The Office of Research Support Services Reminders • Electronic Proposal Submission – – – – All Electronic Submissions are not created equal Read the Instructions Does the PI or Institution need to be registered users? Is the required technology available at the Department? At ORS? – All electronic applications must be approved by ORS before submitting to sponsor even if a paper copy with signatures is required after electronic submission. SPP #2102 Approval of Proposals 58 REVISED February 2014 The Office of Research Services The Office of Research Support Services Reminders continued… • Meet the specifications of the announcement • Make it easy for the reviewers to see that you have done so • Awards are made to the Institution • Only Research Services is authorized to sign on behalf of the University 59 REVISED February 2014 The Office of Research Services The Office of Research Support Services Questions??? 60 REVISED February 2014 The Office of Research Services The Office of Research Support Services Sponsored Programs at Penn Award Acceptance and Account Set-Up 61 REVISED February 2014 The Office of Research Services The Office of Research Support Services What is a Notice of Award (NOA)? • A notice of grant award - also referred to as notice, NOGA, NGA, sponsor notice, contract or award letter - is an official notification from a sponsor indicating that a proposal has been funded. • Notice of grant awards are typically received by the Office of Research Services [Pre-award offices], although on occasion a PI may be notified directly. 62 REVISED February 2014 The Office of Research Services The Office of Research Support Services What is Contained in a Notice of Award • PI Name • Dates of Performance – Current budget period – Total project period • Dollars – Direct, F&A – Current, project total • Cost Sharing • Contact information • General & Special T&C – Use of Animals/Human Subjects – Use of Interest Income – Use of Program Income • Reporting requirements – – – – Programmatic Financial Property Invention 63 REVISED February 2014 The Office of Research Services The Office of Research Support Services Review and Negotiation • ORS Pre-Award and Office of Clinical Research and Center for Technology Transfer staff review sponsor terms and conditions for compliance with University Policy. • Non-standard terms may require negotiation or other measures to harmonize with University Policy. • Selected examples: – Intellectual Property and Tangible Research Policy – Publication – Financial Reporting Requirements – Governing Law – F&A rate (See SPP 2116 Recovery of F&A Costs) 64 REVISED February 2014 The Office of Research Services The Office of Research Support Services Review and Negotiation Considerations Specific to Corporate-Funded Contracts: Expectations of corporate sponsors different from expectations of public sector sponsors: Ownership of data and other intellectual output; Confidentiality of work for which sponsor is paying; Control over publication of research; Responsibility/liability for harm that may arise from research or use of research output’ For clinical trials, rapid, frequently competitive, activation of protocols. 65 REVISED February 2014 The Office of Research Services The Office of Research Support Services Review and Negotiation Considerations Specific to Corporate-Funded Contracts: Internal Review Process Adapted to Accommodate Projects Funded by Corporate Sponsors: Agreements to be forwarded to Office of Clinical Research (for clinical trial agreements) and Center for Technology Transfer (for other research agreements) for negotiation as soon as sponsor is willing to negotiate/final budget; IRB/IACUC submission not required; Only items necessary for negotiation need to be forwarded; See eform in Internal Documents in Penn ERA for step-by-step instructions for this parallel review process. 66 REVISED February 2014 The Office of Research Services The Office of Research Support Services Award example - NIH NOA Section I: • Award Data & Fiscal Information – Summary of totals for current and future years – Fiscal year of award – Indicates whether an unobligated balance has been applied to the award amount – Newly added “PMS Account Type” NOA Section II: – Refers reader to Web site for Grant Payment Information and OIG Hotline Information 67 REVISED February 2014 The Office of Research Services The Office of Research Support Services Award example - NIH NOA Section III: Standard Terms & Conditions • Grant program legislation and regulations • Restrictions on the expenditure of funds in appropriation acts • 45 CFR 74 or 92 as applicable • NIH Grants Policy Statement • Carryover—automatic or prior approval • Included/excluded from Streamlined Noncompeting Award Process (SNAP) • FDP signatory status noted • FAIN number • FFATA/ARRA • Program Income 68 REVISED February 2014 The Office of Research Services The Office of Research Support Services Award example - NIH • NOA Section IV: Specific Terms and Conditions – Revisions – Cooperative Agreement – Restrictive terms – Information items – Staff Contact Information – Spreadsheet Summary 69 REVISED February 2014 The Office of Research Services The Office of Research Support Services Exercise • • • • • • • • • • What is the name of the sponsor? What is the name of Penn’s PI? Is your award a grant or contract? Is your award cost-reimbursable or fixed-price per patient? What is the first year budget period? What is the entire project period? What is the dollar amount obligated under this award? Are there any subcontracts? Will PHS-FITS be required? Bonus: identify 1 or more specific term and condition. 70 REVISED February 2014 The Office of Research Services The Office of Research Support Services Award Example - Foundation • Award layout varies by sponsor • NOA often references terms and conditions not explicitly named 71 REVISED February 2014 The Office of Research Services The Office of Research Support Services Exercise • • • • • • • • • • What is the name of the sponsor? What is the name of Penn’s PI? Is your award a grant or contract? Is your award cost-reimbursable or fixed-price per patient? What is the first year budget period? What is the entire project period? What is the dollar amount obligated under this award? Are there any subcontracts? Will PHS-FITS be required? Bonus: identify 1 or more specific term and condition. 72 REVISED February 2014 The Office of Research Services The Office of Research Support Services Account Set-Up 73 REVISED February 2014 The Office of Research Services The Office of Research Support Services Account Set-Up - Workflow Status Changed To Award From Pending, Future Pending, Advance Account, or Account Continuation Notice of Award (NOA) Received and Negotiation complete FCOI Compliance verified Fund Attributes Fund Parents Special Budgets Account Segments Assigned in PennERA & Sent to GL Fund & Legacy Number Created in BEN Financials & Sent to PennERA AIS is Generated Award Notice Uploaded in PennERA 74 REVISED February 2014 The Office of Research Services The Office of Research Support Services Workflow • Electronic process for imaging awards and updating PennERA – Applies to changes to records that result in AIS • Several steps and roles – Document enters imaging system – Package created and assigned to AD/CA for handling – AD/CA creates account setup summary for package and sends to Operations – Operations updates award, adds package to PennERA • Hurdles: – – – – Is Is Is Is PHS-FITS necessary? Is it complete? there a Non-Competing Continuation transmittal on file? there inconsistency between the package and record? there a Cost-Share form to be signed? 75 REVISED February 2014 The Office of Research Services The Office of Research Support Services Funds and Accounts • New Funds are created for each year of the award when carryover of money from one year to the next must be approved by the Sponsor • New funds are also required when the F&A changes from one segment to another • New funds may be required if the funding mechanism changes at the sponsor • Subaccounts are to be requested on the subaccount worksheet 76 REVISED February 2014 The Office of Research Services The Office of Research Support Services Receiving the Award and the Account Information Sheet (AIS) AIS is issued online. NOAs are uploaded in the Attachments tab in PennERA as part of Workflow. For help: ais-prob@lists.upenn.edu 77 REVISED February 2014 The Office of Research Services The Office of Research Support Services Review the Award • • • • • • AIS is not a substitute for award PI is responsible for all terms Review terms and conditions of award Sponsor guidelines Restrictions Scientific reporting specifications 78 REVISED February 2014 The Office of Research Services The Office of Research Support Services Review the AIS • Ensure Account End Dates Accurate (budget end or project end?) • Ensure Award on AIS matches Award on NOGA • Ensure FDP and/or SNAP • Ensure accuracy of F&A rate • Ensure proper PI name and Org# • If the AIS is for a continuation year, always check for budget periods funded with prior unobligated funds. • If errors occur, email ais-prob@lists.upenn.edu 79 REVISED February 2014 The Office of Research Services The Office of Research Support Services Advance Accounts • What is an Advance Account? – Use when high probability of award – Allows you to put charges on proper account • Avoid journal entries and payroll reallocations – Use with pre-award costs under expanded authorities – Easy to request • ORS Web page has link to Advance Account Request – http://www.upenn.edu/researchservices/pdfs/advance.pdf – PSOM-Advance Accounts are approved and setup by ORSS – All other schools - forward request to ORS Pre-Award 80 REVISED February 2014 The Office of Research Services The Office of Research Support Services Advance Accounts (cont.) • Risks – Award may not materialize – Start date may be delayed – Not all sponsors allow “Pre-award” expenditures • Establish follow-up routine – Has award materialized? – Is something holding it up? – 3 month limit on advance accounts 81 REVISED February 2014 The Office of Research Services The Office of Research Support Services Subaward Process • BA/PI initiates subaward request via Research Inventory System (RIS)*; • Subrawardee enters necessary contact information and returns to ORS via RIS; • ORS completes subrecipient monitoring, generates subaward agreement and sends to subawardee for execution; • RIS sends email notification to BA indicating the subaward is fully executed. Signed agreement is stored in RIS; • BA establishes Purchase Order; • Subaward activity is noted in the RIS activity log throughout the process. *Note: Subaward agreements that were previously created via the paper process will continue via the paper process. 82 REVISED February 2014 The Office of Research Services The Office of Research Support Services Subrecipient Monitoring • A-133 report or audited financial statements required annually • Current F&A rate agreement • Risk Assessment – results indicate appropriate subcontract terms and conditions 83 REVISED February 2014 The Office of Research Services The Office of Research Support Services Questions??? 84 REVISED February 2014 The Office of Research Services The Office of Research Support Services