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Subaward Negotiations Job Aid - Arizona State University

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					                                Subaward Negotiations Job Aid

                                For Work Instruction WI-MS-30
                                                                                           Date: 10-7-11


1. GCO emails "Subrecipient A-133 Audit Form/Audit Certification Financial Status Questionnaire"
document (insert link to document here) to Subrecipient for Completion and Return. Upon receipt of
completed "Subrecipient A-133 Audit Form/Audit Certification Financial Status Questionnaire"
document, GCO will save to to central Sharepoint A-133 Audit Folder:
Research Admin > ORSPA > Award Setup > Shared Documents > Subawards Information > A-133
AUDIT > FY20## Annual Audit Reports > FY2011 Audit Reports + Letters + Review Forms >
"Subrecipient Name A-133 Audit Form Subaward#.doc (naming convention for A-133 Audit Form)"

Save documentation to SharePoint folder based on the Audit Year of the Audit Report.

The "Subrecipient A-133 Audit Form/Audit Certification Financial Status Questionnaire" documentation
received from Subrecipient will be reviewed. The AST GCO will conduct a review of all audit findings
and will identify any material weaknesses and any material instances of noncompliance from federal
laws or regulations and findings which specifically or might potentially relate to Subaward. A
management decision will be made after review. If findings are noted, then Subrecipient's responses
and corrective plans are reviewed. If any additional terms and conditions are decided to be
incorporated into Subaward after review of both Subrecipient Audit documentation and completion of
risk assessment, GCO will incorporate into subaward. For more details on A-133 Subrecipient
Monitoring, see WI-MS-20, entitled "Review A-133 Report".

2. GCO runs Visual Compliance check and assesses for any risk and saves email confirmation or
a print-screen pdf of completed Visual Compliance check to respective subawards folder in Awards
SharePoint site. (Refer to Visual Compliance Restricted Party Screening job aid RPS Screening
for Subawards). Visual Compliance program is maintained by ORIA and program retains all searches
for five years by unit/department.

a. For U.S. and foreign based Universities, include the university name in Visual Compliance check.
b. For U.S. and foreign based industry, include both company name and PI/contact name in Visual
Compliance check.
c. For foreign subrecipients requiring a wire transfer, include Subrecipient’s Bank name in Visual
Compliance check.

3. GCO compares the amount being issued on the subaward agreement with the Direct Cost shown on
1st numeric column on the G210 Grant Summary Report. A copy of the G210 report is saved to
the respective subawards folder in Awards SharePoint site. TOTALS NEED TO MATCH. If the totals
match then no further action required. If the totals do not match then GCO forwards that specific
information to notifications@asu.edu requesting further action, as activation would be required in
order to get the totals to match.    Check COEUS and G-210 to make sure it reflects prime award end
date.

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                               Subaward Negotiations Job Aid

                               For Work Instruction WI-MS-30
                                                                                          Date: 10-7-11



4. GCO looks up Advantage Vendor Information (VEN2 screen) and saves a copy to respective
subawards folder in Awards SharePoint site. If Vendor is not in Advantage, GCO requests
Sub_W9_1A Form and to Guidance Sub W-9 Completion or W-8-BEN Form to be completed by the
Vendor. When the GCO receives the completed form, they complete the Vendor Entry in Advantage
and send W-9 and Screenshot of VE to AdvantageHelp@asu.edu (See Job Aid Advantage Vendor
Entry for Instructions).




Vendor "Remit To" Address - AST GCO is responsible for verifying on the FDP Subaward
Agreement, Attachment 3B (or for Non-FDP Agreements within the Subaward agreement
Invoicing Section of Agreement), that the Financial Contact Name and Financial Contact
Address is the same Name and Address which appears in Advantage. If they do not match,
AST GCO contacts the vendor and confirms which address to use and if different than what
appears in Advantage, AST GCO emails the Subrecipient a "Sub W-9 Form" or "W-8-BEN
Form" requesting completion and return.




5. GCO completes Risk Assessment Tool Form and saves to respective subawards folder in the Awards
SharePoint site. For higher risk subaward agreements, ASU may insert additional
monitoring requirements into the subaward agreement in an effort to better assist in monitoring of
the Subrecipient's technical and financial performance.




6. GCO uses the FFATA Checklist Guidance Document for AST in an effort to determine whether
FFATA Reporting is required on subaward. Completion of this checklist by GCO will assist in making
determination as to which FDP Template Subaward Agreement Attachment(s) and fields within the
FDP Subaward Agreement Attachments require completion by Subrecipient in an effort by ASU to be
sure to capture all the data elements required for FFATA Reporting. This is a step in the process,
completed checklist does not need to be uploaded to SharePoint, as GCO will indicate FFATA "Yes" or
"No" in SharePoint task.




7. GCO selects which Subaward Agreement Template to use for subaward.



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                               For Work Instruction WI-MS-30
                                                                                          Date: 10-7-11

NOTE: IF CFDA# FOR SUBAWARD, THEN ALWAYS USE THE ESTABLISHED FDP TEMPLATE FOR ALL
FEDERALLY AND SUB-FEDERALLY FUNDED SUBAWARDS.


Always be sure to use the most current subaward agreement templates established on SharePoint for
team use.

Current templates are continually updated and available on AST SharePoint site for use:
Home > Research Admin > ORSPA > Award Setup > Shared Documents > Subawards Information
(The practice of always using templates from AST SharePoint, and never saving any templates to
desktop to use will assure that AST is always using the most current templates, as templates are
continually updated.)

Letter of Understanding (LOU) Template Agreement - Always use established LOU template with all
Subawards issued to NAU or UofA.

Fixed Price Template Agreement - Always use Fixed Price Template for foreign subrecipients and can
be used for other subrecipients likewise as needed. Always use the established FDP Foreign Subaward
Agreement template for all federally and sub-federally funded foreign subawards.

FDP Subaward Agreements

FDP (Federal Demonstration Partnership) Subaward Templates are used for all federally funded or
sub-federally funded subawards. An individual template has been established specifically for each of
the following sponsors (If federally/sub-federally funded and not one of these sponsors, then use the
FDP Template established for use for all other federal sponsors):

           AFOSR
           AMRMC
           ARO
           DOE
           NASA
           NIH
           NSF
           ONR
           USDA
           EPA:
            EPA funded subawards included the following requirement:
            All subrecipient invoices in excess of $25,000 funded by EPA prime agreements
            will require at least quarterly submission of detailed supporting documentation to
            Arizona State University to verify the allowability and appropriateness of charges.

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                                  For Work Instruction WI-MS-30
                                                                                            Date: 10-7-11



           Supporting documentation must be submitted by Subrecipient for the following
           types of expenditures:

                            ·     Salaries and wages (acceptable forms of documentation include
                            time sheets, pay detail by employee, certified efforts if available);
                        ·       Consultant fees in excess of $5,000 per consultant (consulting
                            agreement with evidence of daily rate);
                        ·   Domestic travel in excess of $5,000 per trip (source documents for
                            travel);
                        ·   Foreign travel (source documents for travel);
                        ·   Capital purchases (source documents for purchase);
                        ·       Current F&A and/or ERE rate agreement if rates have changed
                            during the Subaward period.

The FDP (Federal Demonstration Partnership) subaward agreement templates may be used by any
institution, regardless if an institution is an FDP member or not.

FDP Templates were established in coordination with Federal agencies represented on the FDP which
approved the use of the forms and federal participants in the FDP were a part of the Task Force that
created and tested the forms. However, the FDP makes no representation or warrantees regarding the
suitability of these forms for use on any federal or non-federal sponsored projects. All users utilize
these forms at their own risk.


FDP WEBSITE: http://sites.nationalacademies.org/PGA/fdp/index.htm

The FDP Agreement templates are saved on Award Setup Team (AST) SharePoint site and are
comprised of the following attachments:
Home > Research Admin > ORSPA > Subcontracts > TEMPLATES > FDP SUBAWARD AGREEMENT
TEMPLATES

a)   FDP Research Subaward Agreement Facepage (1 page), Attachment 1 (1 page) , Attachment 3A,
(1 page), Attachment 3B (2 pages), Attachment 4 (2 pages), Attachment 5 (2 pages).

b)   Each of the following sponsors has its own unique Attachment 2 containing sponsor approved
terms and conditions, so GCO will choose the appropriate Attachment 2 based on Sponsor to
incorporate with FDP Subaward Agreement.

          AFOSR
          AMRMC


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                               For Work Instruction WI-MS-30
                                                                                      Date: 10-7-11

          ARO
          DOE
          EPA
          NASA
          NIH
          NSF
          ONR
          USDA
          Independent Attachment 2 (An independent Attachment 2 is inserted into FDP Template
           for use with any Federal Sponsors other than AFOSR, AMRMC, ARO, DOE, EPA, NASA, NIH,
           NSF, ONR, USDA, as each of those sponsors already has an approved FDP Attachment 2
           for use.)

c)    If the subaward contains ARRA funding, GCO will then need to incorporate FDP Template ARRA
Funding Attachment 4A (6 pages) as part of the Subaward Agreement.

Home > Research Admin > ORSPA > Subcontracts > TEMPLATES > FDP SUBAWARD AGREEMENT
TEMPLATES > ARRA Funding_Attachments

d)    If the subaward contains ARRA funding, and sponsor is NIH or NSF, GCO will then also need to
incorporate either FDP's approved “Attachment 2_ARRA NIH” template or FDP's approved “Attachment
2_ARRA NSF” template accordingly as part of the Subaward Agreement.

Home > Research Admin > ORSPA > Subcontracts > TEMPLATES > FDP SUBAWARD AGREEMENT
TEMPLATES > ARRA Funding_Attachments

e)   Fixed Price Template Agreement - use for foreign subrecipients.

8. ASU Subrecipient Commitment Form captures some of the data elements required by ARRA and
Federal Funding Accountability and Transparency Act (FFATA or Transparency Act). AST is continuing
to work on enhancements to procedures to be able to conduct effective and efficient ARRA and
FFATA reporting.

a. When using an FDP subaward agreement, the following required data elements are also required to
be entered into the FDP subaward agreement.

b. The following required data elements are also entered into COEUS under "Admin"."Organization":

"Vendor" (Vendor Number)




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"Congressional District (i.e. if it is in the State of Arizona's 5th district, enter "AZ-005") ASU must
track Federal funding to its subrecipients in the amount of $25,000 or more, by Congressional District,
per the Federal Funding Accountability and Transparency Act (FFATA). To find a copy of the bill go to
http://www.thomas.gov/cgi-bin/cpquery/T?&report=sr329&dbname=109. To find a Congressional
District go to https://forms.house.gov/wyr/welcome/shtml. (Note: Foreign awards are not excluded
for national security reasons and are tracked in the same manner as domestic subawards. Certain
data requirements (such as Congressional District information) may not pertain to foreign
subawards. )

"D-U-N-S Number" (Dun and Bradstreet Data Universal Numbering System) The D-U-N-S number is a
widely used unique nine character identification number used by both commercial and federal entities
and was adopted as the standard business identifier for federal electronic commerce in October 1994.
The DUNS number is available free of charge from the commercial company Dun & Bradstreet. A
vendor must have a D-U-N-S number to register in Central Contractor Registration (CCR) and is the
key vendor identifier used in CCR. CCR is the government-wide registration system for entities that
do business with the Federal Government, which stores information about recipients, including
financial account information for payment purposes and a link to Dun and Bradstreet for maintaining
current D-U-N-S information.

"DUNS +4" (Enter only if provided with a DUNS+4. The DUNS+4 refers to the D-U-N-S number
assigned by Dun & Bradstreet, plus a 4-character suffix that is assigned by the vendor to establish
additional CCR records for identifying alternative EFT accounts for the same vendor located at the
same physical address. Dun & Bradstreet has no affiliation with the 4 character suffix.)

NOTE:
Subrecipients are required to maintain current D-U-N-S number and to maintain current registration in
the CCR database. AST GCO is to obtain D-U-N-S number from Subrecipient.
AST GCO is to confirm that Subrecipient maintains a current CCR registration.
AST GCO will verify that Subrecipient's CCR Registration is current by accessing Central Contractor
Registration webpage and typing in D-U-N-S number as search criteria:
https://www.bpn.gov/CCRSearch/Search.aspx.
Proof of registration in process from Subrecipient will suffice to meet this requirement.
AST GCO enters the date Subrecipient "CCR Registration is valid thru" within respective field in
SharePoint task.
AST GCO saves proof of CCR Registration to Awards Folder.

"SUBRECIPIENT 5 MOST HIGHLY COMPENSATED OFFICERS"

If, in the subrecipient’s preceding fiscal year, the subrecipient


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                                 Subaward Negotiations Job Aid

                                 For Work Instruction WI-MS-30
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·        received 80 percent or more of its annual gross revenues from Federal contracts (and
subcontracts), loans, grants (and subgrants) and cooperative agreements; and
·        received $25,000,000 or more in annual gross revenues from Federal contracts (and
subcontracts), loans, grants (and subgrants) and cooperative agreements; and
·        the public does not have access to information about the compensation of the senior
executives through periodic reports filed under Section 13(a) or 15(d) of the Securities
Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or Section 6104 of the Internal Revenue
Code of 1986, then Subrecipient is required to provide Name/Title & Total
Compensation of its five most highly compensated Officers.


"SUBRECIPIENT “PLACE OF PERFORMANCE” ADDRESS"
If Subaward “Place of Performance” address differs from Subrecipient “Award”
address then Subrecipient is required to provide Place of Performance.
If Subaward includes a "Place of Performance" address differing from Subrecipient
"Award" Address, then that address is then added by GCO into the COEUS Maintain
Organization Rolodex. After saving the "Place of Performance" address in COEUS
Maintain Organization, GCO edits the Subaward within COEUS Subcontracts
Module by selecting "Contacts" tab, Select "Add", then search for the address and
select respective address, use drop down menu and select "Place of Performance"
as the Contact Type. One can have several addresses saved to "Contacts" Tab per
each subaward.
NOTE: AS IT IS AN FFATA REQUIREMENT TO CAPTURE SUBRECIPIENT'S 9-DIGIT
ZIP (ZIP+4) ADDRESS, GCO WILL VERIFY IN COEUS THAT 9-DIGIT ZIP (ZIP+4)
ADDRESS FOR IS CAPTURED IN COEUS FOR SUBRECIPIENT "AWARD" ADDRESS
AND "PLACE OF PERFORMANCE" ADDRESS, IF IT DIFFERS FROM AWARD ADDRESS.



9. GCO reviews documents for consistency and completeness with Notice of Award (NOA).



10. Period of Performance
As standard practice going forward, all sub agreements will be issued for the same period of
performance for which the prime award has been funded. Exceptions to this process will be instances
where:

     1. the sub agreement was proposed and budgeted for a shorter duration than the prime award;
or
     2. the Principal Investigator specifically requests a different period of performance for a particular


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                                Subaward Negotiations Job Aid

                                For Work Instruction WI-MS-30
                                                                                            Date: 10-7-11

sub agreement. In this case, the PI and Research Advancement staff will need to notify their Award
Management team member when the sub agreement is ready for modification.




11. Prior to sending agreement to PI for review/approval, GCO will verify that they have received A-
133 required documentation (as detailed earlier in Work Instruction) from subrecipient, if not,
GCO will request it again, as it will have to be reviewed and management decision made prior to
subaward execution, as outlined in WI-MS-20. Specific guidance for how to address findings and
deficiencies that are encountered when reviewing A-133 Audit Reports is currently being developed, as
well as the specific terms and conditions which would be recommended to be negotiated into
subaward agreements to address particular findings and deficiencies. These additional requirements
for Terms and Conditions will be added to Work Instructions once they have been developed and
defined.   In the interim, risk mitigating Terms and Conditions will be developed specific to individual
subawards to enhance subrecipient monitoring until the matrix document has been completed.



12. GCO prepares and emails draft subaward agreement documents (subaward agreement; cost/price
analysis; request for subaward) to Principal Investigator (cc: RA) requesting review and email
approval and/or any requested revisions.

This is the point that documentation should be reviewed by both PI and RA for any inaccuracies in
details (i.e. Period of Performance, Budget, Statement of Work) and should be pointed out by PI or
RA to the Award Setup Team GCO.




13. Principal Investigator will send back any requested changes if necessary and/or approval.




14. After correction, if necessary, resubmit via email to Principal Investigator (cc: RA) requesting
review and email approval.




15. NOTE: If GCO is sending a 2nd/3rd/... email request to Principal Investigator (cc: RA) requesting
approval, please also make a courtesy phone call that you are sending documentation for
review/approval, as a courtesy to notify that subaward will be on hold until approval is received. This
will assist in turn around processing time of subaward.




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                               Subaward Negotiations Job Aid

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                                                                                         Date: 10-7-11

16. GCO saves Principal Investigator (PI) email approval to respective subawards folder in Awards
SharePoint site. When GCO receives Sole Source Justification from PI, GCO will need to
retype it on the Request for Subaward form so it is easy for Purchasing to find when they
are reviewing the documentation folder to issue purchase order.




17. GCO saves completed copy of Cost/Analysis Form (with backup documentation) and completed
Request For Subaward Form document to respective subawards folder in Awards SharePoint site.




18. GCO sends Subaward Agreement document (insert link to document here) to Subrecipient for
Review and Signature

          GCO emails subaward agreement to Subrecipient (cc: Principal Investigator) requesting
           review, completion, signature, scan and the return of partially executed sub award
           agreement and any applicable Representations and Certifications (e.g. IRB Approval,
           IACUC Approval) as required. GCO will not be able to issued subaward agreement to
           subrecipient until ASU has received IRB Approval/IACUC Approval, if applicable to the
           Subaward Statement of Work. If Subrecipient requests any exception, which would
           be rare (i.e. Subrecipient states that Animal/Human Subjects will not be until Year 2 of
           Subaward Agreement, GCO will need to forward any of these exception requests to
           ORIA for review/approval, as subaward cannot be issued until ASU has received IRB
           Approval/IACUC Approval.
          GCO will attach the Prime Award to the email to the Subrecipient.
          GCO must ensure that the CFDA # is included in the Subaward Agreement document.
          NOTE: If Agreement is an LOU (Letter of Understanding), which are issued between ASU
           and UofA or between ASU and NAU, then AST Assistant Director can sign the LOU first and
           then send to UofA or NAU respectively for countersignature and return to ASU for further
           processing.

Additional steps when subaward agreement language revisions are required:

          GCO negotiates as necessary.

          When material changes are made to subaward agreement language, GCO sends e-mail to
           Principal Investigator (cc: RA) informing of the changes and requests Principal Investigator
           review and email approval of revised and final Subaward Agreement.




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                              Subaward Negotiations Job Aid

                              For Work Instruction WI-MS-30
                                                                                       Date: 10-7-11

           GCO saves Principal Investigator email approval to respective subawards folder in Awards
           SharePoint site.

          GCO emails final Subaward Agreement to Subrecipient (cc: PI) requesting Subrecipient to
           review, print, sign, scan, and email the signed Subaward Agreement back to assigned
           GCO.
          GCO includes the "Subrecipient A-133 Audit Form" as an attachment to the email.
          GCO will attach the Prime Award to the email to the Subrecipient.

19. Subrecipient returns the signed/completed Subaward agreement to ASU AST GCO

           Subrecipient returns the signed/completed Subaward agreement to ASU
           AST GCO.

          If it is noted on Agreement by Subrecipient that they do not have a current CCR
           Registration or DUNS#, AST GCO will send the "DUNS CCR Registration
           Information Template" to the Subrecipient. Subaward will not be issued until
           Subrecipient has met the requirement for CCR/DUNS Registration. To meet the
           DUNS requirement, subrecipient is required to provide DUNS number. To meet
           the CCR requirement, Subrecipient must either maintain a current
           CCR Registration or provide proof that their CCR Registration is currently being
           processed. AST GCO will verify that the subrecipient has completed all required
           informational fields on agreement, and has signed the agreement.

20. Prior to GCO submitting subaward agreement to Assistant Director for review and ASU Signature,
GCO confirms the following:

All required fields have been completed by Subrecipient on the Subaward Agreement, no required
fields have been left blank (i.e. CFDA Number is always required, required checkboxes have been
checked, etc..)

The dollar amounts and data on the Cost/Price Analysis Form are accurate and total matches the total
dollar amount shown on the Subaward Agreement.

The dollar amounts and data on the Request for Subaward Form are accurate and matches the total
dollar amount on the Subaward Agreement.

If IRB/IACUC approval was required, that the approval has been obtained and saved to SharePoint.




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                               Subaward Negotiations Job Aid

                               For Work Instruction WI-MS-30
                                                                                         Date: 10-7-11

GCO confirms that the following items are saved in respective subawards folder within Awards
Sharepoint site using the (Guidance Subaward Documents needed to process subaward) template and
using Naming Convention "Agency/Org Item # - Descriptor for Document".




           • Agency/Org Item A - Subrecipient Commitment Form (all attachments)
           • Agency/Org Item B - Budget Justification
           • Agency/Org Item C - Cost Price Analysis & Sole Source Justification

           • Agency/Org Item D – G-210 Grant Summary Report printout
           • Agency/Org Item E – GCO A-133 or Audit Certification and Financial Status Questionaire
           Audit Risk Review – see Subaward Negotiations Job Aid


          Agency/Org Item F - Visual Compliance Verification
          Agency Org Item G - Subaward Risk Assessment Completed
          Agency/Org Item H - Advantage (Vendor Information Printou)
          Agency/Org Item I - PI Approval (email)
          Agency/Org Item J - email sent to subreceipient with fully executed subaward attached
               Fully executed Subaward Agreement
               IRB/IACUC Approval (if required for subaward)
               CCR Check - using DUNS number
               Other Documentation and email documentation (as necessary)


The following items should be saved by the GCO for ASU Assistant Director to review prior to fully
executing new subaward however; once ASU Purchasing confirms SC number than the GCO can
delete the following items from the Subaward Sharepoint Task site in order to save space on
Sharepoint site. The reason these can be deleted is that they are already saved on another site on
Sharepoint or are incorporated as part of the subaward itself or are not neccesary to keep.


          Agency/Org Item K - Prime Award
          Agency/Org Item L - Scope of Work (SOW)
          Agency/Org Item M - Budget
          Agency/Org Item N - A133 Audit Report or Audit Certification or Financial Status
           Questionnaire
          Agency/Org Item O - PI Approval Request
          Agency/Org Item P - Subaward sent to Subrecipient for Signature (email)
          Agency/Org Item Q - Partially signed Subaward Received from Subrecipient (email)

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           Agency/Org Item R - Partially executed subawar sent to ASU Ass't Dir. for
            approval/signature (email)
           Agency/Org Item S - Email to ASU Purchasing requesting issuance of SC for new subaward
           Agency/Org Item T - Email from Purchasing confirming setup of Subaward and SC number




NOTE: If Subrecipient is subject to the audit requirements of OMB Circular A-133, they are
required to complete and return "Subrecipient A-133 Audit Form" with link included to
Audit Report. If Subrecipient is not subject to the audit requirements of OMB Circular A-
133, they are required to complete and return "Audit Certification and Financial Status
Questionnaire". In addition, Subrecipient might be asked to provide a limited scope audit,
before a subaward will be issued. Whether a subrecipient is subject to the audit
requirements of OMB Circular A-133 is outlined within the "Subrecipient A-133 Form" itself.


NOTE: All documentation received will be saved to Sharepoint A-133 Audit Folder:


Home > Research Admin > ORSPA > Award Setup > Shared Documents > Subawards
Information > A-133 AUDIT > FY20## Annual Audit Reports > FY2011 Audit Reports +
Letters + Review Forms > "Subrecipent Name Audit Report.pdf" (naming convention for
Audit Reports) or "Subrecipient Name Review Form Subaward#.doc (naming convention for
Review Forms)"




21. GCO sends email to Assistant Director requesting review of Subaward Agreement and signature.
GCO's email contains the link to the respective subawards folder within Awards SharePoint which
contains fully executed subaward for signature as well as documentation received to date.



22. After ASU Assistant Director’s signature is obtained, the signed subaward agreement is routed
back from Assistant Director to GCO for further processing.

23. GCO updates "Fully Executed Date" in SharePoint task with the date of the final signature on the
subaward.



This documentation will be saved to central Sharepoint A-133 Audit Folder:
Research Admin > ORSPA > Award Setup > Shared Documents > Subawards Information > A-133




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                               Subaward Negotiations Job Aid

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AUDIT > FY20## Annual Audit Reports > FY2011 Audit Reports + Letters + Review Forms >
"Subrecipient Name Review Form Subaward#.doc (naming convention for Review Forms)"

           NOTE: Save to respective SharePoint folder based on the Audit Report "Audit Year".

           NOTE ON A-133 Audit Report Review (this step is referenced in WI-NS-20):
           If Subrecipient is subject to the audit requirements of OMB Circular A-133, they are
           required to complete and return "Subrecipient A-133 Audit Form".
           If Subrecipient is not subject to the audit requirements of OMB Circular A-133, they are
           required to complete and return the "Audit Certification and Financial Status
           Questionnaire".
           Whether a subrecipient is subject to the audit requirements of OMB Circular A-133 is
           outlined within the "Subrecipient A-133 Audit Form" itself.

NOTE: Save to respective SharePoint Share Documents folder based on the Audit Year of the Audit
Report.




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