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Subrecipient Policy: Difference between revisions
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width="20">[[Intellectual Property]]</td> | width="20">[[Intellectual Property]]</td> | ||
<td style="border-bottom:2px solid #A3B1BF" width="3"> </td> | |||
<td style="padding:0.5em; background-color:#e5e5e5; font-size:90%; line-height:0.95em; border:1px solid #A3B1BF; border-bottom:solid 2px #A3B1BF" | |||
width="20">[[Faculty]]</td> | |||
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[[Sponsored Programs]] | [[ | [[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]] | ||
<br /><br /> | <br /><br /> | ||
Policy No.: '''6108'''<br /> | Policy No.: '''6108'''<br /> | ||
Effective Date: '''11 | Effective Date: '''11/24/08'''<br /> | ||
Revised Date: ''' '''<br /> | Revised Date: ''' '''<br /> | ||
Reviewed Date: ''' '''<br /> | Reviewed Date: '''01/17/13 '''<br /> | ||
<br /> | <br /> | ||
<big>'''Subrecipient Policy'''</big> | <big>'''Subrecipient Policy'''</big> | ||
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== 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 /><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. | |||
== Explanation of Key Concepts == | == Explanation of Key Concepts == | ||
*When UNMC receives a federal award, UNMC is considered the primary recipient (or “prime”) of the federal funds and the subrecipient is the organization that receives the subcontract from UNMC. | *When UNMC receives a federal award, UNMC is considered the primary recipient (or “prime”) of the federal funds and the subrecipient is the organization that receives the subcontract from UNMC. | ||
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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. OMB Circulars A-133 and A-110 contain definitions of vendor and subrecipient. In summary: | ||
*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 OMB Circular A-133 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: | ||
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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 Senior Manager, Financial Compliance and Cost Analysis] | ||
[http://www.unmc.edu/media/spa/subrecipientmonitoring.doc UNMC Subrecipient Monitoring Procedures] | *[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] | ||
* | *OMB Circular A-133, Audits of States, Local Government, and Non-Profit Organizations (June 2003) | ||
* | *OMB Circular A-133, Compliance Supplement (March 2007) | ||
* | *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 | This page maintained by [mailto:dpanowic@unmc.edu dkp]. | ||