In addition to being UConn Health’s authorized representative for grants, contracts and other agreements from government agencies, private industry, and non-profit foundations and the central point of coordination for sponsored projects, Sponsored Program Services administers grants and contracts on behalf of UConn Health.

Activities include establishing new awards and budgets in the UConn Health’s accounting system (Banner) and assisting with pre-award coding requests, approving and processing re-budgets of expenditures, cost transfers, no-cost extensions and preparation of final financial reports.Awards Management also provides guidance and consultation on issues such as applicable regulations, allowable costs, cost share and match requirements as well as monitoring account activity for adherence to terms and conditions of awards and applicable policies and regulations.All grant management policies at UConn Health are derived from Federal, State and University policies and regulations such as Office of Management and Budget Uniform Grant Guidance.

 

The Research Subaward Agreement (RSA) is used to issue a subaward to a collaborating institution on a grant or contract. It is the responsibility of the Principal Investigator (PI) to prepare the required documents for the RSA.

During the life of the subaward, the PI monitors technical progress, compliance with all applicable laws and regulations, and reporting requirements.

The PI reviews subrecipient’s invoices before payment and submits all invoices, including the final invoice, to SPS for review and to ensure that all costs are allowable and that cost share has been met.

» Subaward/Project Agreement Request Form.

When SPS has set up a new award and consulting services are anticipated, the Department will initiate the contract request by submitting a requisition in HuskyBuy.

Submiting a requisition in HuskyBuy for consultant services.

a. If the vendor (consultant) is not available in HuskyBuy, obtain a Form W-9 from the vendor and create the new vendor request through the requisition in HuskyBuy.

b. Complete the Contract Request Form (CRF), using Account Code 78510 (Grant contract consultant) and attach to HuskyBuy requisition

Amendments and Multi-year Agreements:

For new multi-year Agreements, enter the full project period in Banner, but only enter committed funds for Year 1.

 

 

When SPS has set up a new award that has a subaward component, the Department will receive an email with the fund number. The Department will then:

1. Submit a requisition in HuskyBuy.

• If the vendor (Subrecipient) is not available in HuskyBuy, obtain a completed and signed Form W-9 from the vendor and create the new vendor through HuskyBuy.
• Proper account codes to use on the requisition
  • 78501 – Grants Federal Subcontracts under $25,000
  • 78502 – Grants Federal Subcontracts over $25,000
  • 78503 – Grants Subcontracts with indirect costs (IDC)
  • 78504 – Grants Subcontracts with no indirect copsts (IDC)

2. Attach the following documents:

• FDP Agreement Request Form
• Information and Compliance form for Subrecipients
• Subrecipient SOW, budget and budget justification
• Subrecipient Compliance approvals, if applicable

3. SPS will confirm receipt and send the Department a final draft to review before sending the Subaward Agreement out for Subrecipient signature.

Amendments

Amendments will be used to make any necessary changes to the Agreement. Amendment requests are submitted in HuskyBuy by the PI or designee. SPS will draft and send the Amendment to the Subrecipient and encumber the funds in HuskyBuy by approving the PO.

 

 

Grant-funded research collaborations usually involve issuing a Subaward to the collaborating institution.  Subaward Agreements are used to issue grant funds to Subrecipients.  A Consultant PSA should be used to contract for consulting services.  All grant-funded Subawards are managed through SPS before they are sent to and signed by the Subrecipient.  Consultant PSAs are handled through HuskyBuy by SPS and Procurement and Contracts.

Subaward versus Consultant

A recipient of a Subaward (Subrecipient) is usually an institution that collaborates with the UConn Health Principal Investigator (PI).  The Subrecipient performs, and has responsibility for, part of a sponsored project.  Its services are of a specialized and specific nature and cannot be performed by UConn Health.  A Subrecipient is normally reimbursed for expenses in accordance with a budget.  UConn Health has the responsibility to monitor Subrecipient performance.

A Consultant may be an individual or an organization.  The Consultant assists the UConn Health PI. Consulting services are primarily advisory in nature and address a clearly delineated problem or provide a fee-for-service function.  A Consultant is normally paid based on an hourly or daily rate or on a fixed price for deliverables.

Consultant versus Employee

A Consultant PSA should not to be used in place of hiring regular full-time, part-time, or temporary employees.  Furthermore, a Consultant PSA is not appropriate for the hiring of individuals to teach classes or to perform work that has been recognized as belonging to one of the collective bargaining units within the State System.   Retired members of the State Employee Retirement System cannot be placed on PSAs. Instead, they are to be placed on Special Payroll in 120-day positions. If an employer/employee relationship exists and the contractor is acting as an employee, the Department needs to contact the Department of Human Resources for information and assistance.

Assistance

Subawards and Consultant PSAs should be submitted through HuskyBuy.

Submitting Invoices for Payment

The Principal Investigator (PI) must approve invoices for payment. This task may not be delegated.

SPS will not approve and Accounts Payable will not issue a payment for invoices which are not signed by the PI (delegation is not permitted).

Resolving Invoice Issues

• If the PI identifies a concern with subrecipient performance, the PI will request clarification from the subrecipient PI.
• If the department grant administrators identify any unusual, apparently excessive, or potentially unallowable charges invoiced by a subrecipient and if the explanations from the subrecipient are insufficient to render a prudent judgment on the allowability of the cost, the department grant administrator shall refer the matter to SPS for resolution with the subrecipient’s institutional authorities.
• When SPS is satisfied that the issues are resolved, they will notify the department and PI to proceed with approval for payment. Invoices will not be approved for payment until all issues or concerns have been resolved.

 

Risk Monitoring and Compliance

• At least annually, SPS will review subrecipient’s financial stability, financial processes, and controls as follows:
  •  A-133 entities: Subrecipients that expend $750,000 or more of federal funds annually are subject to Uniform Guidance (UG). SPS relies on the accuracy and veracity of subrecipient data submitted on the Federal Demonstration Project database for this purpose (Harverster). Upon review of Harvester data, if  the subrecipient discloses findings related to the management of sponsored awards receipt of an unfavorable audit report, SPS will confirm that the subrecipient has taken appropriate and timely corrective action.  SPS will issue a management decision letter stating if additional terms and conditions are part of the subrecipient agreement as a means to mitigate risk.
  • Subrecipients not subject to A-133 or the Uniform Guidance audit requirements: Annual audited financial statements or responses to questions regarding financial status and systems to be completed as part of the Subrecipient Profile Questionnaire will be requested and reviewed by SPS.
• SPS will review subrecipient compliance certifications annually to ensure they are current in accordance with the applicable regulations.

Closeout of Subawards

SPS, in collaboration with department administrators and/or PI, will begin subaward closeout actions immediately following conclusion of the subaward period of performance. Subawards will be processed for closeout and formally closed within a 60-day time period, unless SPS grants the department an extension. A subaward may not be formally closed until all of the following closeout requirements have been met:

• Final review of costs charged to UConn Health and final close-out of all commitments, accrued costs, or payables
• Receipt of final invoice from subrecipient and Subrecipient Release and Certification Form
• Receipt of all required deliverables as specified in the subaward, patent/invention documentation, and equipment reports. Final verification of technical completion will be indicated by the PI’s signature and date on the final invoice

• SPS, the PI, and department grant administrators will jointly determine the frequency and scope of departmental monitoring procedures. A “risk-based” approach to subrecipient monitoring is recommended with the frequency and intensity of monitoring driven by the terms of the prime award and the risk assessment.
• PIs will monitor the progress of subrecipient work scope at least on a quarterly basis
• Options for review include informal progress reports via phone conversations, e-mail communications, or face-to-face discussions, formal technical reports or other deliverables specified in the agreement required and due on specific dates. Subrecipient invoices will be submitted to the PI
• Subrecipient is required to submit invoices adhering to the following criteria:
  • Expenditures are reported for current period and cumulative period
  • Expenditures are itemized by cost category
  • Cost share and/or match is reported on each invoice
  • Invoice must also include the following:
    • Subrecipient’s name and address
    • Subaward Agreement Number and UConn Health fund number
    • Project period and period of invoice
    • Invoice number and date prepared
    • Subrecipient contact person with respect to the invoice
    • Certification on each invoice as to the truth and accuracy of the invoice
  • Final Invoice must be submitted by subrecipient within sixty (60) days of end date
• PI will review and approve invoices from subrecipients to ensure that:
  • Expenditures are consistent with the proposed budget
  • Costs are incurred within the period of performance and are allowable
  • Expenses are aligned with technical progress
  • Cost sharing is appropriately reflected if required
• The PI must sign the invoice to indicate that review has been completed and that the invoice has been approved for payment.

For UConn Health proposals to external sponsors in which a potential subawardee is identified, the Principal Investigator (PI) must include the following documents for each potential subawardee.

• Information and Compliance Form for Subrecipients
• Subrecipient budget and agreed upon scope of work
• F&A rate agreement
• Other information that may be required by sponsors, such as compliance certifications, biographical sketches, current and pending support, and available facilities pages

Risk Assessment

The subrecipient must complete and submit a Subrecipient Profile Questionnaire, which allows UConn Health to identify financial weaknesses related to management of sponsored funds.  A risk assessment is completed based on the subrecipient Profile Questionnaire, the Information and Compliance form, and most current single audit for subrecipient. Where the risk assessment reveals a high potential for financial risk, a proposed risk mitigation strategy will be developed by SPS before proceeding with the subaward. The risk assessment takes into account several factors, including:

• Type of subrecipient organization (for-profit/not-for-profit/small business/corporation/foreign/domestic)
• Whether the subrecipient is subject to Uniform Guidance or other federal financial review. Subrecipients not subject to Uniform Guidance audit requirement will provide more information regarding their financial status and systems as part of the Subrecipient Profile Questionnaire
• Award size relative to the subrecipient’s sponsored research portfolio
• Award complexity, sensitivity of the work, and complexity of the governing regulations
• UConn Health’s prior experience with the subrecipient
• Subrecipient location (i.e., remoteness from the UConn Health might require more oversight);
• Organizational and individual conflict of interest

Issuing a Subaward

In order to initiate a subaward, the PI or designee submits a requisition in HuskyBuy, which must include the FDP Agreement Request form, subrecipient SOW, budget, budget justification and any applicable compliance approvals.

• SPS reviews the documents, drafts a Research Subaward Agreement, sends to PI for review and approval, and forwards it to the subrecipient for signature
• SPS negotiates terms with the subrecipient if necessary, countersigns the agreement
• SPS distributes copies of the subaward to the subrecipient and PI.  A copy is retained in SPS’ award file

Standard Terms in Subawards

The UConn Health subawards generally will include the following terms and conditions:

• Mandatory flow-down provisions from the prime award, such as the requirements of applicable federal laws and regulations
• Payment terms, including but not limited to: fixed price or cost reimbursement, termination, billing and invoice certification requirements
• Ownership of intellectual property and data
• For federal awards, the CFDA number, prime award number, and the federal agency sponsoring the award
• Requirement permitting the sponsor and UConn Health and their auditors to have access to the records and financial statements as necessary for the University to conduct a review as necessary
• For subrecipients subject to Uniform Guidance, a requirement to report any problem related to the subaward identified in their annual audits

Post-Award Subrecipient Monitoring

UConn Health is responsible for monitoring the activities of subrecipients to ensure that awarded funds are used for authorized purposes and that performance goals are achieved.