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Subrecipient Policy: Difference between revisions
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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: ''' | Reviewed Date: '''08/11/22 '''<br /> | ||
<br /> | <br /> | ||
<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. | |||
== 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. | 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. | 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 | *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. | 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 | *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. | *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] | ||
* | *[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/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]. | ||