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Subgrants Subcontracts Training

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Subgrants Subcontracts Training
Subgrants & Subcontracts Training
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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 is part of the Prime
Award objectives/deliverables
◦ The site will be responsible for programmatic decision
making related to the project/study under the Prime
Award
◦ The site will be held accountable to the compliance
regulations of the Prime Award (COI, Publication, IP,
etc)
◦ The site will use the Prime Award funds to carry out
its own programmatic work
◦ Special circumstances…
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
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Service & Vendor
Agreements
A service/vendor agreement
is appropriate when the
outside entity is not
contributing to the end goal
of the project.
 Storage (drug, supplies,
etc.)
 Website design &
management for a clinical
trial.
Set up through Purchasing,
not ORA.

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
Agreements under
 800 Accounts
Agreements drafted and
negotiated by appropriate
ORA director
File and Purchase order
created and managed by
subs team
(http://ssc.jhmi.edu/supplychain/forms/index.
html)
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Subgrants under Federal grants
Subcontracts under Federal and state
contracts
Subgrants under awards from foundations
Subcontracts under commercial contracts
Funding from multiple sources
◦ Please try to make us aware of all the sources of funding
(commercial and non-commercial) for the subaward

Internal JHU awards
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NTAP – Neurofibromatosis Therapeutic
Acceleration Program
ABTC – Adult Brain Tumor Consortium
TBCRC – Translational Breast Cancer
Consortium
PACKARD – The Robert Packard Center for
ALS Research
CRN – Clinical Research Network (AAHSRI,
GBMC, INOVA, PRMC, RHMC
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ORA Operations
Analyst sends
NGA to
ORASubcontracts
@jhmi.edu email
Subsite
sends back
sub.
Potentially,
negotiations
follow.
Subsite
signs sub
and sends
back to Subs
Team
member,
with other
required
docs.
Coordinator
contacts
departmental
contact for docs
Subs Team
member
creates
shopping
cart in SAP.
(It must be
approved).
Subs Team
member
enters
purchase
order
number on
sub or
updates PO
Departmental
contact sends
information to
Coordinator
Subs Team
member
requests
sub-IO, also
known as
the “96
number”.
Subs team
member
provides
PE
contract,
email from
site, and
folder to
Subs
Manager
Manager
signs and
provides
file to
Coordinator
Subs Team
member
sends
contract
draft to
subsite.
Coordinator sends
FE sub to
the
subsite,
the dept.
contacts
and PI
Coordinator
creates file and
forwards
information to
Subs Team
Member
Subs Team
Member
evaluates
information
and drafts the
subcontract
and submits it
for supervisory
review
Coordinator cleans
& closes file
folder &
completes
and closes
log entry
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
For an original sub:
A Subaward Information Sheet
A budget for the subsite
A statement of work for the subsite
IRB/IACUC approval for the subsite
Wire transfer agreements for subsites in foreign
countries
 Conflict of Interest Documentation (Federal Prime)
 And for Federal subs to foreign entities and domestic
start up companies … Sub risk questionnaire, DUNS #,
SAM registration
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For modifications:
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A Subaward Information Sheet
A budget
A statement of work (but only if it has changed)
Updated IRB/IACUC approval
Conflict of Interest Documentation (Federal Prime)
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


[email protected] for processing and
assignment to a Subawards Team Member
In most cases, Subawards are assigned to the Subawards
Team members by SOM department.
BUT 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, 800’s
◦ Michelle:
 Subs under foundation awards
 Modifications of subcontracts under federal contracts
 ABTC
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
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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 every 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)
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 (or amount for the
PO)
Information related to the Study for Clinical Trials
Information related to Transfer of equipment or materials.
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
Budgets for subs under Federal grants should include:
 Names of personnel
 Breakdown of costs for equipment, supplies, and “other
expenses”
 Explanation of travel costs


In all 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.
 Federal sponsors generally do not allow funding for office
supplies and computers.
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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.
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.
◦ For example, the site will be paid $10,000 for every five patients it enrolls
in a clinical trial.


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.
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IRB and IACUC approvals
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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 fullyexecute the Agreement.
KKI and the CRN site
Study Team Members
should be included as
part of the JHU IRB
Wire transfer agreements



Contains bank account
and payment
information for the
Subsite.
Must be on Subsite
letterhead or stamped
with an official stamp
from the Subsite
After completion, the
departmental contact
must send the WTA to
Accounts Payable.
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
Under Federal grants and contracts, all
Subrecipients must be registered in the
System for Award Management (“SAM”), and
must also have a DUNS number
◦ SAM website: https://sam.gov
◦ DUNS number requests: http://fedgov/dnd.com/webform

High Risk Subrecipient Monitoring:
◦ ORA will send all High Risk Subrecipients a Welcome Packet and
Subrecipient Questionnaire
 (Each site only needs to complete the questionnaire if they have not
had any activity with the University in the last year).
◦ High Risk Subrecipients must submit invoices on template included as
exhibit to the Sub Agreement.
◦ JHU PI must submit a certification to AP with each invoice
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

As of 8/24/12: Subsites are required to submit
COI information at the time of JHU application
via Subrecipient Commitment Form distributed
to the depts by the JHU Grants Associates.
2 Options:
◦ Complete, and certify best ability at time of JHU application
◦ Certify that they are registered in FDP Clearinghouse


Subs team will use the SCF to choose language
for the Agreement
If SCF was not completed at time of JHU
application, Subs team will send FCOI form to
site with Agreement.
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Under Federal subs…(MTDC)
 For subs under federal grants and contracts, JHU takes additional IDC
on the first $25K of the subcontract budget.
 If there are multiple subs to the same site under one grant, JHU will
only charge IDC once.
o Ex: Proj A, Core, Proj B under P50 – all to UMB, different PI’s = multiple
96s and POs but only one 96 will be charged additional JHU IDC.
Under non-Federal agreements…(TDC)
 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 commercial subcontracts, 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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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


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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
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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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 In order for us to close out a P.O., the department must
have already received the final invoice.
 After a P.O. is closed, any money left on it should
automatically move back to the IO number.
 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 Supply Chain.
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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.
Department contact and PI review invoice and obtain
necessary signatures.
Departmental contact sends invoice 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.
All invoices for high risk subsites must be submitted to
AP with a certification signed by the PI. Keep a running
tab of all of the invoices that have been submitted, and
ensure that there is funding left in account.
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
When reviewing invoices, departmental contacts
should:
◦ Confirm with the PI that the work has been performed
and that any necessary reports have been submitted. PI
should be aware of payments.
◦ Check that P.O. number and account number are correct.
◦ Time period of invoice should coincide with previous
invoice. Shouldn’t overlap with previous invoice and
should NEVER exceed the termination date.
◦ Confirm that IDC rate is correct.
◦ Confirm that budget adds up correctly.
◦ Be sure that cumulative amount invoiced is less than or
equal to total amount of the subaward/subcontract.
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
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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.


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
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
Complicating factors in completing a sub:
◦ 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

Please do NOT:
◦ 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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
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Generally speaking, the Subs group cannot
resolve BW and Real Time Grant Report issues
(incorrect encumbrances, etc.) that do not
involve our adjustments to the corresponding
purchase order.
However, we can try to guide department
contacts to get in touch with people who
should be able to assist in the situation.
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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.
Subawards Manager
443-287-0701
[email protected]
Michelle Sloan, M.H.A.
Subawards Associate
410-614-1716
[email protected]
Laura Gethers, M.P.A.
Subawards Specialist
(410) 502-3342
[email protected]
Victoria Lefevers, M.A.
Subawards Specialist
410-502-0776
[email protected]
Subawards Coordinator
410-502-0558
[email protected]
Melody Snow, M.H.S.
Paul Stuart, B.S.
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