Subrecipient Policy: Difference between revisions

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[[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]]
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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 />
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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]


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