Subrecipient Policy - Revision history

Mhurlocker: /* Additional Information */

2024-08-19T19:40:33Z

Additional Information

← Older revision		Revision as of 14:40, August 19, 2024
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	*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.331 § 200.331 Subrecipient and contractor determinations, Uniform Guidance on Requirements for pass-through entities]		*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.331 § 200.331 Subrecipient and contractor determinations, Uniform Guidance on Requirements for pass-through entities]

	This page maintained by [mailto:~~dpanowic~~@unmc.edu ~~dkp~~].		This page maintained by [mailto:mhurlocker@unmc.edu mh].

Mhurlocker at 19:02, August 14, 2023

2023-08-14T19:02:08Z

← Older revision		Revision as of 14:02, August 14, 2023
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	</table>		</table>
	<br />		<br />
	[[Sponsored Programs]] \| [[Sponsored Programs Costing]] \| [[Institutional Base Salary]] \| [[Sponsored Project Cost Share]] \| [[Effort Certification]] \| [[Cost Transfer]] \| [[Service Center]] \| [[Subrecipient Policy]] \| [[On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects~~]] \| [[FDA Regulated Research~~]]		[[Sponsored Programs]] \| [[Sponsored Programs Costing]] \| [[Institutional Base Salary]] \| [[Sponsored Project Cost Share]] \| [[Effort Certification]] \| [[Cost Transfer]] \| [[Service Center]] \| [[Subrecipient Policy]] \| [[On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects]]
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Mhurlocker at 16:57, August 3, 2023

2023-08-03T16:57:32Z

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	</table>		</table>
	<br />		<br />
	[[Sponsored Programs]] \| [[Sponsored Programs Costing]] \| [[Institutional Base Salary]] \| [[Sponsored Project Cost Share]] \| [[Effort Certification]] \| [[Cost Transfer]] \| [[Service Center]] \| [[Subrecipient Policy]] \| [[On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects]]		[[Sponsored Programs]] \| [[Sponsored Programs Costing]] \| [[Institutional Base Salary]] \| [[Sponsored Project Cost Share]] \| [[Effort Certification]] \| [[Cost Transfer]] \| [[Service Center]] \| [[Subrecipient Policy]] \| [[On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects]] \| [[FDA Regulated Research]]
	<br /><br />		<br /><br />

Afaylor: undated Financial Compliance and Cost Analysis and 2x UNMC Subrecipient Monitoring Procedures links

2023-03-31T16:17:09Z

undated Financial Compliance and Cost Analysis and 2x UNMC Subrecipient Monitoring Procedures links

Dpanowic at 20:29, August 17, 2022

2022-08-17T20:29:51Z

← Older revision		Revision as of 15:29, August 17, 2022
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	<big>'''Subrecipient Policy'''</big>		<big>'''Subrecipient Policy'''</big>
	== Basis of the Policy ==		== Basis of the Policy ==
	Acceptance of federal awards obligates the University of Nebraska Medical Center (UNMC) to comply with the federal government’s rules, regulations and guidelines applicable to sponsored programs. Federal cost principles ~~per the~~ [https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1 Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or Uniform Guidance 2 CFR, Part 200] pertaining to grants and contracts ~~involving federal funds~~.		Acceptance of federal awards obligates the University of Nebraska Medical Center (UNMC) to comply with the federal government’s rules, regulations and guidelines applicable to sponsored programs. Federal cost principles contained in [https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1 Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or Uniform Guidance 2 CFR, Part 200] pertaining to federal grants and contracts must be followed.
	== Purpose of the Policy ==		== Purpose of the Policy ==
	As a condition of its acceptance of funding from sponsors, UNMC is obligated in its role as primary recipient to undertake certain stewardship activities as well as to comply with federal, state and local regulations. When UNMC assigns responsibility for conducting a portion of the work sponsored by an award to a subrecipient, UNMC remains responsible to the sponsor for both the management of funds and the meeting of performance goals. The purpose of this policy is to detail how UNMC will comply with these obligations<br />		As a condition of its acceptance of funding from sponsors, UNMC is obligated in its role as primary recipient to undertake certain stewardship activities as well as to comply with federal, state and local regulations. When UNMC assigns responsibility for conducting a portion of the work sponsored by an award to a subrecipient, UNMC remains responsible to the sponsor for both the management of funds and the meeting of performance goals. The purpose of this policy is to detail how UNMC will comply with these obligations<br />

Dpanowic at 16:17, August 11, 2022

2022-08-11T16:17:37Z

← Older revision		Revision as of 11:17, August 11, 2022
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	</table>		</table>
	<br />		<br />
	[[Sponsored Programs]] \| [[~~Direct Cost~~]] \| [[Institutional Base Salary]] \| [[Sponsored Project Cost Share]] \| [[Effort Certification]] \| [[Cost Transfer]] \| [[Service Center]] \| [[Subrecipient Policy]] \| [[On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects]]		[[Sponsored Programs]] \| [[Sponsored Programs Costing]] \| [[Institutional Base Salary]] \| [[Sponsored Project Cost Share]] \| [[Effort Certification]] \| [[Cost Transfer]] \| [[Service Center]] \| [[Subrecipient Policy]] \| [[On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects]]
	<br /><br />		<br /><br />

Dpanowic at 16:07, August 11, 2022

2022-08-11T16:07:42Z

← Older revision		Revision as of 11:07, August 11, 2022
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	</table>		</table>
	<br />		<br />
	[[Sponsored Programs]] \| [[~~Sponsored Programs Costing]] \| [[Facilities and Administrative~~ Cost]] \| [[Institutional Base Salary~~]] \| [[Unallowable Cost Policy~~]] \| [[Sponsored Project Cost Share]] \| [[Effort Certification]] \| [[Cost Transfer]] \| [[Service Center]] \| [[Subrecipient Policy]] \| [[On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects]]		[[Sponsored Programs]] \| [[Direct Cost]] \| [[Institutional Base Salary]] \| [[Sponsored Project Cost Share]] \| [[Effort Certification]] \| [[Cost Transfer]] \| [[Service Center]] \| [[Subrecipient Policy]] \| [[On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects]]
	<br /><br />		<br /><br />

Dpanowic at 16:03, August 11, 2022

2022-08-11T16:03:32Z

← Older revision		Revision as of 11:03, August 11, 2022
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	<big>'''Subrecipient Policy'''</big>		<big>'''Subrecipient Policy'''</big>
	== Basis of the Policy ==		== Basis of the Policy ==
	Acceptance of federal awards obligates the University of Nebraska Medical Center (UNMC) to comply with the federal government’s rules, regulations and guidelines applicable to sponsored programs. Federal cost principles per the Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or Uniform Guidance 2 CFR, Part 200 pertaining to grants and contracts involving federal funds.		Acceptance of federal awards obligates the University of Nebraska Medical Center (UNMC) to comply with the federal government’s rules, regulations and guidelines applicable to sponsored programs. Federal cost principles per the [https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1 Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or Uniform Guidance 2 CFR, Part 200] pertaining to grants and contracts involving federal funds.
	== Purpose of the Policy ==		== Purpose of the Policy ==
	As a condition of its acceptance of funding from sponsors, UNMC is obligated in its role as primary recipient to undertake certain stewardship activities as well as to comply with federal, state and local regulations. When UNMC assigns responsibility for conducting a portion of the work sponsored by an award to a subrecipient, UNMC remains responsible to the sponsor for both the management of funds and the meeting of performance goals. The purpose of this policy is to detail how UNMC will comply with these obligations<br />		As a condition of its acceptance of funding from sponsors, UNMC is obligated in its role as primary recipient to undertake certain stewardship activities as well as to comply with federal, state and local regulations. When UNMC assigns responsibility for conducting a portion of the work sponsored by an award to a subrecipient, UNMC remains responsible to the sponsor for both the management of funds and the meeting of performance goals. The purpose of this policy is to detail how UNMC will comply with these obligations<br />
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	*[http://info.unmc.edu/management/finance/fincompliance/index.html Financial Compliance and Cost Analysis]		*[http://info.unmc.edu/management/finance/fincompliance/index.html Financial Compliance and Cost Analysis]
	*[http://www.unmc.edu/media/spa/subrecipientmonitoring.doc UNMC Subrecipient Monitoring Procedures]		*[http://www.unmc.edu/media/spa/subrecipientmonitoring.doc UNMC Subrecipient Monitoring Procedures]
	*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1 Uniform Guidance]		*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1 Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or Uniform Guidance 2 CFR, Part 200]
	*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.331 § 200.331 Subrecipient and contractor determinations, Uniform Guidance on Requirements for pass-through entities]		*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.331 § 200.331 Subrecipient and contractor determinations, Uniform Guidance on Requirements for pass-through entities]

	This page maintained by [mailto:dpanowic@unmc.edu dkp].		This page maintained by [mailto:dpanowic@unmc.edu dkp].

Dpanowic at 15:56, August 11, 2022

2022-08-11T15:56:41Z

← Older revision		Revision as of 10:56, August 11, 2022
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	Policy No.: '''6108'''<br />		Policy No.: '''6108'''<br />
	Effective Date: '''11/24/08'''<br />		Effective Date: '''11/24/08'''<br />
	Revised Date: ''' '''<br />		Revised Date: '''08/11/22 '''<br />
	Reviewed Date: '''01/17/13 '''<br />		Reviewed Date: '''08/11/22 '''<br />
	<br />		<br />
	<big>'''Subrecipient Policy'''</big>		<big>'''Subrecipient Policy'''</big>
	== Basis of the Policy ==		== Basis of the Policy ==
	~~The~~ University of Nebraska Medical Center (UNMC) ~~recognizes its responsibility to act as a good steward of public funds. Therefore as a component of that stewardship, it is the policy of UNMC~~ to comply with federal regulations (OMB ~~Circulars A-110 & A-133~~) pertaining to grants and contracts involving federal funds.		Acceptance of federal awards obligates the University of Nebraska Medical Center (UNMC) to comply with the federal government’s rules, regulations and guidelines applicable to sponsored programs. Federal cost principles per the Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or Uniform Guidance 2 CFR, Part 200 pertaining to grants and contracts involving federal funds.
	== Purpose of the Policy ==		== Purpose of the Policy ==
	As a condition of its acceptance of funding from sponsors, UNMC is obligated in its role as primary recipient to undertake certain stewardship activities as well as to comply with federal, state and local regulations. When UNMC assigns responsibility for conducting a portion of the work sponsored by an award to a subrecipient, UNMC remains responsible to the sponsor for both the management of funds and the meeting of performance goals. The purpose of this policy is to detail how UNMC will comply with these obligations~~<br />~~<br />		As a condition of its acceptance of funding from sponsors, UNMC is obligated in its role as primary recipient to undertake certain stewardship activities as well as to comply with federal, state and local regulations. When UNMC assigns responsibility for conducting a portion of the work sponsored by an award to a subrecipient, UNMC remains responsible to the sponsor for both the management of funds and the meeting of performance goals. The purpose of this policy is to detail how UNMC will comply with these obligations<br />

	'''Note:''' This policy does not include agreements for [[Vendors\|vendors]], including items such as: consulting services or purchase orders for equipment, materials or other services, as explained below.		'''Note:''' This policy does not include agreements for [[Vendors\|vendors]], including items such as: consulting services or purchase orders for equipment, materials or other services, as explained below.
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	:*For example, if UNMC subcontracts part of an NIH award to another university, there is no contractual relationship between NIH and the other university.		:*For example, if UNMC subcontracts part of an NIH award to another university, there is no contractual relationship between NIH and the other university.
	=== Explanation of Vendors ===		=== Explanation of Vendors ===
	Determination of whether the relationship is that of a subrecipient or a vendor is critical. ~~OMB Circulars~~ A-~~133 and A~~-~~110 contain~~ definitions of ~~vendor~~ and ~~subrecipient~~. ~~In summary:~~		Determination of whether the relationship is that of a subrecipient or a vendor is critical. [https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1 Uniform Guidance] contains definitions of vendors and subrecipients.
	*Vendors generally supply goods and services that are necessary to the completion of a project but are not part of a cooperative programmatic effort.		*Vendors generally supply goods and services that are necessary to the completion of a project but are not part of a cooperative programmatic effort.
	*Vendors supply essential services or products to a program as a routine part of their daily business and are not subject to ~~OMB Circular A-133~~ or the compliance requirements of the award terms and conditions.		*Vendors supply essential services or products to a program as a routine part of their daily business and are not subject to Uniform Guidance or the compliance requirements of the award terms and conditions.

	== Policy ==		== Policy ==
	It is the policy of UNMC to comply with federal regulations regarding subrecipient monitoring, when UNMC is the prime recipient of a federal award or contract. The following are the key compliance requirements:		It is the policy of UNMC to comply with federal regulations regarding subrecipient monitoring, when UNMC is the prime recipient of a federal award or contract. The following are the key compliance requirements:
	*Federal agencies ~~clearly~~ hold prime recipients responsible for establishing monitoring systems and controls to give reasonable assurance that subrecipients are in compliance with federal policies.		*Federal agencies hold prime recipients responsible for establishing monitoring systems and controls to give reasonable assurance that subrecipients are in compliance with federal policies.
	:*This means that when UNMC subcontracts part of a federal award to another organization, UNMC remains fully responsible to the federal government for the entire award (since UNMC is the “Prime”).		:*This means that when UNMC subcontracts part of a federal award to another organization, UNMC remains fully responsible to the federal government for the entire award (since UNMC is the “Prime”).
	*Properly executed subcontract agreements protect both UNMC and the subrecipient institutions by making clear the subrecipient’s responsibilities.		*Properly executed subcontract agreements protect both UNMC and the subrecipient institutions by making clear the subrecipient’s responsibilities.
	*The subcontracting agreement lays the groundwork for the collaborative arrangement between UNMC and the other organizations. A well-structured and inclusive contract is required.		*The subcontracting agreement lays the groundwork for the collaborative arrangement between UNMC and the other organizations. A well-structured and inclusive contract is required.
	*Clear understandings of the respective roles and compliance with the terms and conditions of the award by Principal Investigators at both institutions are vital to the success of the project.		*Clear understandings of the respective roles and compliance with the terms and conditions of the award by Principal Investigators at both institutions are vital to the success of the project.
	*The monitoring of technical and financial activities associated with a subrecipient is an integral part of UNMC’s stewardship of sponsor funds.		*The monitoring of technical and financial activities associated with a subrecipient is an integral part of UNMC’s stewardship of sponsor funds.
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	*[http://info.unmc.edu/management/finance/fincompliance/index.html Financial Compliance and Cost Analysis]		*[http://info.unmc.edu/management/finance/fincompliance/index.html Financial Compliance and Cost Analysis]
	*[http://www.unmc.edu/media/spa/subrecipientmonitoring.doc UNMC Subrecipient Monitoring Procedures]		*[http://www.unmc.edu/media/spa/subrecipientmonitoring.doc UNMC Subrecipient Monitoring Procedures]
	*~~OMB Circular~~ A-~~133, Audits of States, Local Government, and Non~~-~~Profit Organizations (June 2003)~~		*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1 Uniform Guidance]
	*~~OMB Circular~~ A-~~133, Compliance Supplement (March 2007)~~		*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.331 § 200.331 Subrecipient and contractor determinations, Uniform Guidance on Requirements for pass-through entities]
	*OMB Circular A-~~110~~, Uniform ~~Administrative~~ Requirements for ~~Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non~~-~~Profit Organizations (September 1999)~~
	*OMB Circular A-21, Cost Principles for Higher Education (May 2004)

	This page maintained by [mailto:dpanowic@unmc.edu dkp].		This page maintained by [mailto:dpanowic@unmc.edu dkp].

Dpanowic at 17:20, January 7, 2020

2020-01-07T17:20:31Z

← Older revision		Revision as of 12:20, January 7, 2020
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	</table>		</table>
	<br />		<br />
	[[Sponsored Programs]] \| [[Sponsored Programs Costing]] \| [[Facilities and Administrative Cost]] \| [[Institutional Base Salary]] \| [[Unallowable Cost Policy]] \| [[Sponsored Project Cost Share]] \| [[Effort Certification]] \| [[Cost Transfer]] \| [[Service Center]] \| [[Subrecipient Policy]]		[[Sponsored Programs]] \| [[Sponsored Programs Costing]] \| [[Facilities and Administrative Cost]] \| [[Institutional Base Salary]] \| [[Unallowable Cost Policy]] \| [[Sponsored Project Cost Share]] \| [[Effort Certification]] \| [[Cost Transfer]] \| [[Service Center]] \| [[Subrecipient Policy]] \| [[On-Campus and Off-Campus Indirect Cost Rates on Federally Sponsored Projects]]
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	Refer to the Subrecipient Monitoring Procedures for specific obligations and guidance.		Refer to the Subrecipient Monitoring Procedures for specific obligations and guidance.
	== Additional Information ==		== Additional Information ==
	*[mailto:mhrncirik@unmc.edu Manager, Financial Compliance and Cost Analysis]		*[mailto:mhrncirik@unmc.edu Senior Manager, Financial Compliance and Cost Analysis]
	*[http://info.unmc.edu/management/finance/fincompliance/index.html Financial Compliance and Cost Analysis]		*[http://info.unmc.edu/management/finance/fincompliance/index.html Financial Compliance and Cost Analysis]
	*[http://www.unmc.edu/media/spa/subrecipientmonitoring.doc UNMC Subrecipient Monitoring Procedures]		*[http://www.unmc.edu/media/spa/subrecipientmonitoring.doc UNMC Subrecipient Monitoring Procedures]

← Older revision		Revision as of 11:17, March 31, 2023
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	*Clear understandings of the respective roles and compliance with the terms and conditions of the award by Principal Investigators at both institutions are vital to the success of the project.		*Clear understandings of the respective roles and compliance with the terms and conditions of the award by Principal Investigators at both institutions are vital to the success of the project.
	*The monitoring of technical and financial activities associated with a subrecipient is an integral part of UNMC’s stewardship of sponsor funds.		*The monitoring of technical and financial activities associated with a subrecipient is an integral part of UNMC’s stewardship of sponsor funds.
	*The specific systems and controls adopted by UNMC for establishing and monitoring subrecipients are found in the UNMC [~~http~~://www.unmc.edu/~~media~~/~~spa~~/~~subrecipientmonitoring~~.~~doc~~ Subrecipient Monitoring Procedures] that explain all of the monitoring roles and responsibilities for:		*The specific systems and controls adopted by UNMC for establishing and monitoring subrecipients are found in the UNMC [https://www.unmc.edu/spa/subcontracts/subrecipient-monitoring-procedure.html Subrecipient Monitoring Procedures] that explain all of the monitoring roles and responsibilities for:
	:*Principal Investigators		:*Principal Investigators
	:*Sponsored Programs Administration		:*Sponsored Programs Administration
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	== Additional Information ==		== Additional Information ==
	*[mailto:mhrncirik@unmc.edu Senior Manager, Financial Compliance and Cost Analysis]		*[mailto:mhrncirik@unmc.edu Senior Manager, Financial Compliance and Cost Analysis]
	*[~~http~~://info.unmc.edu/management/finance/fincompliance/index.html Financial Compliance and Cost Analysis]		*[https://info.unmc.edu/management/finance/fincompliance/index.html Financial Compliance and Cost Analysis]
	*[~~http~~://www.unmc.edu/~~media~~/~~spa~~/~~subrecipientmonitoring~~.~~doc~~ UNMC Subrecipient Monitoring Procedures]		*[https://www.unmc.edu/spa/subcontracts/subrecipient-monitoring-procedure.html UNMC Subrecipient Monitoring Procedures]
	*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1 Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or Uniform Guidance 2 CFR, Part 200]		*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1 Office of Management and Budget’s (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards or Uniform Guidance 2 CFR, Part 200]
	*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.331 § 200.331 Subrecipient and contractor determinations, Uniform Guidance on Requirements for pass-through entities]		*[https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/subject-group-ECFR031321e29ac5bbd/section-200.331 § 200.331 Subrecipient and contractor determinations, Uniform Guidance on Requirements for pass-through entities]

	This page maintained by [mailto:dpanowic@unmc.edu dkp].		This page maintained by [mailto:dpanowic@unmc.edu dkp].