Florida Atlantic University by 4JG85w


									                                                               FloridaAtlantic University
                                                                 Division of Research
                                                  Subcontract and Monitoring Guidance Grid
        Principal Investigator (PI)                            Sponsored Programs (SP)                              Research Accounting (RA)
                                                            BEFORE Issuance of Subcontract
1. Determine the need for subcontracting:              1. Review Subcontract Application for                1. Assist Pre-Award with risk assessment
                                                       eligibility:                                            regarding A-133 Audit Reports.
  a. Identify a subcontractor; or
  b. Issue a Request for Proposal (RFP)                   a. Verify if the contract is the acquisition of
                                                        goods and services to determine a vendor
2. Potential subcontractors are required to fill out   from a subcontractor
   Subaward Application:                                  b. Verify ifthe organization is debarred
                                                          c. Budget evaluation (cost analysis) to
  a. Subaward Application Form includes:                     determine allowability, allocability and
    □ Scope of Work                                          reasonableness
    □ Detailed Budget                                     d. Review most current A-133 Audit (contact
    □ Financial Conflict of Interest                   RA for assistance, if needed)
    □ Financial Profile                                   e. Determine if there are export control
Note: If a subcontractor application has not              f. Determine financial conflict of interest
    been submitted in full during the                     g. Assess level of risk associated with the
    proposal stage, an application will be                    proposed subcontractor (low, medium, high)
    required in order to issue a subcontract
    agreement.                                         2. Inform PI of approval and the risk level
                                                          assessed. If risk level is “high,” then
3. Review and approve subcontract application,            General Counsel is required to approve
   and forward to SP for further approval.
                                                       3. Upon receiving award notification and
4. Upon approval from SP, the PI will request             approval, SP will negotiate an agreement
   a Letter of Intent (LOI) from the subcontractor        with the subcontractor
   to be submitted withthe proposal.
                                                       4. Prepare subcontract agreement for execution
                                                          DURING the Subcontract Agreement
1. Establish and maintain channels of                  1. Process no cost extensions; when applicable       1. Maintain documentation for monitoring
   communication with subcontractor; perform                                                                   efforts
   on-site visits, if applicable                       2. Process amendments; when applicable
                                                                                                            2. Request and review annual A-133 Audit
2. Review and ensure that invoices are:                                                                        Reports or audited financials

  a. Submitted in a timely manner                                                                           3. Review A-133 reports or other audited
  b. Expenses are allowable, allocable and                                                                     Financial statements for material
      reasonable                                                                                            weaknesses, reportable conditions, current
  c. Expenses are incurred within the period of                                                                audit findings and prior audit finding
     performance                                                                                            resolutions
  d. Expenses are aligned with technical
      progress                                                                                                a. If a finding is reported and is related to the
  e. Cost-sharing is appropriately reflected;                                                                   project that FAU has subcontracted for,
      if applicable                                                                                             then General Counsel will be requested to
  f. Invoices are approved by PI or their                                                                       review to determine if a management
     designee and forwarded to A/P for payment                                                                  decision is required

3. Review technical progress to ensure perform-                                                             4. Issue Management Decision; when applicable
   ance goals are achieved; and identify any
   problems in carrying out the project                                                                       a. Notify PI and SP issued management
                                                                                                                 decisions, when applicable
  a. PI is required to fill out a semi-annual
    Subcontractor Verification Form                                                                         5. Assist PI in carrying out their monitoring
4. If changes occur with the prime or sub-
contractor; the SP must be notified in order                                                                  a. Issuing semi-annual and close-out
   to amend an agreement                                                                                         Subcontractor Verification Forms

5. Approve close-out                                                                                        6. Close-out

  a. PI is required to fill out a Subcontractor
    Verification Form

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