Subaward Basics and Subrecipient Monitoring Pilot

Subrecipient Basics and Monitoring

Presented by:Office of Sponsored Projects Revised 05/03/2021 a

Topics Covered

▪ Course Objectives and Overview

▪ Definitions

▪ Subrecipient/Vendor Determination

▪ Preparing a Proposal that Includes a Subrecipient

▪ Preparing, Negotiating, and Executing Subawards

▪ Subaward Setup Process

▪ Subaward Invoicing Process

▪ Subrecipient Monitoring

▪ Closeout of Subawards

▪ Retention of Subrecipient Records

▪ Course Takeaways2

Course Objectives

As a result of attending this course, you will:

✓ Understand the roles and responsibilities of individuals involved in the subaward

process.

✓ Be able to differentiate between a subrecipient and a vendor relationship.

✓ Have a better understanding of Yale’s policies and procedures related to

subrecipients.

✓ Learn the requirements and expectations for subrecipient monitoring and the

processing of subrecipient invoices.

✓ Know where to locate resources to assist in the subaward process.

3

Course Overview

Post-awardPre-award

Subrecipient/VendorDetermination

Preparing a Proposal that includes a Subrecipient

Preparing, Negotiating and Executing Subawards

Subaward Setup Process

Processing Subaward Invoices

Subrecipient Monitoring

Closeout of Subawards

Subrecipient RecordsRetention

4

Definitions

Research

▪ A systematic study directed toward fuller scientific knowledge or understanding of

the subject studied.

Subrecipient (also referred to as a subawardee or subcontractor, or subgrantee)

▪ A legal entity that receives a subaward from Yale under a sponsored award made to Yale.

▪ Accountable to Yale for the use of the funds in carrying out a portion of the programmatic

effort under Yale’s award.

Subaward (also referred to as a subgrant, subcontract, or subagreement)

▪ A legal instrument between Yale and a legal entity in which Yale provides funds (or

property in lieu of funds) to the legal entity to perform a substantive portion of Yale’s

sponsored award.

5

Definitions (continued)


▪ Activities undertaken to review the financial status, management controls, and performance of a subrecipient in order to mitigate risk when contracting with a subrecipient organization

Vendor

▪ A dealer, distributor, merchant, or other seller providing goods or services during normal business operations and that are required for the conduct of a sponsored project

▪ Operates in a competitive environment

Supplier

▪ For purposes of subaward invoice payment, in the Workday system a subrecipient is a Supplier

6

Pre-award: Subrecipient/Vendor Determination

Post-awardPre-award

Subrecipient/Vendor

Determination








7

Principal Investigator (PI)

• Identifies work that needs to be done by a non-Yale entity

• Consults with Office of Sponsored Projects (OSP) and DBO, to determine the appropriate relationship

Department Business Office (DBO) / Administrator

• Assists PI with the subrecipient/vendor determination

• Ensures that all required subrecipient documentation is sent to OSP for review

Office of Sponsored Projects (OSP)

• Provides guidance to PI and DBO on subrecipient versus vendor determination

• Reviews and approves required subrecipient documents

Subrecipient/Vendor Determination: Roles & Responsibilities

8

Subrecipient/Vendor Determination

• Carries out research authorized by Yale’s award

• Measures performance against the objectives of Yale’s award

• Has responsibility for programmatic decision-making

• Receives funds to carry out its own program

• Exercises considerable discretionary judgment

• Provides matching funds or cost sharing as required

• Provides goods or services for the direct benefit of an award

• Sells similar goods or services as part of its normal business operations

• Operates in a competitive environment

• Provides services of a repetitive nature or goods of a commonly available kind

• Provides goods or services that are ancillary to the operation of the prime award program

Vendor ConsiderationsSubrecipient Considerations

1307 PR.01 Establishing Subrecipients Associated with Sponsored Programs 9

https://your.yale.edu/policies-procedures/procedures/1307-pr01-establishing-subrecipients-associated-sponsored-programs

Determine: Subrecipient or Vendor

Other Considerations

▪ There is a responsible individual at the identified entity

– Subrecipient

▪ The entity is free to decide how to carry out the activities requested of it

– Subrecipient

▪ Publications are anticipated

– Subrecipient

▪ There is a potential that patentable or copyrightable technology will be created or reduced to practice by the entity’s PI

– Subrecipient

▪ The activity to be performed is a series of repetitive tests or activities requiring little or no discretionary judgment

– Vendor

10

Subrecipient/Vendor Determination: Comparisons

If a vendor is identified incorrectly as a subrecipient,

what can happen?

If a subrecipient is identified incorrectly as a vendor,

what can happen?

If either a vendor or subrecipient is misidentified,

what can happen?

If on a federal award, Yale would only receive F&A costs on the first $25,000 of expenses (and should receive full F&A)

Unnecessary risk assessmentwould be conducted

Unnecessary additional regulatory requirements could be imposed

on the entity

Entity would inappropriately own the work product

If on a federal award, the vendor would be assessed F&A costs on the entire amount

invoiced rather than the first $25,000

The entity would not be aware of Federal compliance requirements and

flow down provisions

The entity would not have any intellectual property (IP) or publication rights

Yale’s procurement policies regarding proper bidding and

sole source requirements may be violated

The expenses posted would not be included in the correct expense

category for reporting and audit purposes

11

Test Your Knowledge #1

Subrecipient or Vendor?

Case Studies

Case Study 1: Subrecipient/Vendor Determination

▪ A Yale PI identified an entity that is in the business of

tracking, storing, and processing blood specimens. These

services are necessary for the PI in order for her to conduct

her research. The activities carried out by this entity include:

– Sending out blood shipping kits to genetic research centers

– Receiving blood from the genetic research centers

– Transferring DNA to the sponsor

▪ Question: Are these the type of activities of a subrecipient or a vendor?

▪ Why? (Provide several reasons to support your choice.)

▪ What should the proposal preparer do?

13

Case Study 1: Subrecipient/Vendor Determination (continued)

14

▪ Answer: Vendor

▪ Why?

– Providing a service

– No responsibility for programmatic decision making

– Little or no discretionary judgment exercised

– Similar services provided to many different purchasers within its normal business operations

– No publications expected by the entity

– No patentable or copyrightable technology expected

– No rights to intellectual property involved


– Receive a quote from the entity and complete a sole source justification if this is the only vendor that can perform the work

– Budget for the services/goods and apply the full F&A rate in the proposal

Case Study 2: Subrecipient/Vendor Determination

▪ A Yale PI identified an off-site lab that will help him

complete the specific aims of his research award. The lab’s

scope of work includes the following:

– Conducting experiments focused on examining the structure, processing, and function

of a plasma enzyme.

– Providing Yale with a technical report that includes evaluations of the experiments and

conclusions.

– Publishing articles in a scientific journal in collaboration with the Yale PI.

▪ Question: Are these the type of activities of a subrecipient or a vendor?

▪ Why? (Provide several reasons to support your choice.)

▪ What should the proposal preparer do? 15

Subrecipient/Vendor Determination: Case Study #2 (continued)

▪ Answer: Subrecipient

▪ Why?

– Performance measured against the objectives of the award. In this case, it is against the

specific aims of the proposal.

– Responsible for programmatic decision making

– Rights to its intellectual property

– Publications


– Budget the Lab as a subrecipient in the proposal and apply the F&A rate accordingly.

Secure a completed Subrecipient Compliance Information (SIC) form or Letter of

Intent (LOI), as appropriate, and related subrecipient proposal documents.

16

http://your.yale.edu/sites/default/files/1304fr03a_subrecipient_information_and_compliance_form.pdf

Pre-award: Preparing a Proposal that includes a Subrecipient

Post-awardPre-award


Preparing a Proposal that

includes a Subrecipient







17


• Determines work and deliverables required of the subrecipient

• Ensures subrecipient submits all Yale and sponsor required forms


• Assists PI with the completion of all Yale and sponsor required forms

• Ensures all required subrecipient documentation (SIC or LOI) is complete and sent to OSP


• Reviews subrecipient’s documents

• Verifies COI compliance for NSF< PHS, and PHS-like sponsors

• Reviews, approves, and submits completed Yale proposal to sponsor

Preparing a Proposal that Includes a Subrecipient: Roles & Responsibilities

18

Preparing a Proposal that Includes a Subrecipient

Required Subrecipient Documents

▪ Completed and signed SIC form or LOI

– SIC (Subrecipient Information and Compliance) form should be used by all subrecipients submitting a proposal to Yale, with the exception of subrecipients who are members of Federal Demonstration Partnership (FDP).

– Letters of Intent (LOI), are required for Federal Demonstration Partnership institutions only.• The FDP is an association of federal agencies and academic research institutions that work to streamline the administration of

federally sponsored research.

• FDP members use LOIs in lieu of SIC forms to obtain information needed to issue a subaward and monitor a subrecipient entity.

▪ Subrecipient Statement/Scope of Work (SOW)

▪ Subrecipient Budget and Budget Justification

– Subrecipient F&A Rate Agreement (unless the entity is an FDP institution)

▪ Additional sponsor specific requirements may include:

– Biosketches, Current and Pending or Support Page, consortia and/or proposal endorsement letter, etc.

• Per 2 CFR 200, ff an organization does not have a federally negotiated F&A rate, they may elect to propose and charge a de minimis rate of 10% of MTDC*.

• F&A costs under grants to foreign and international organizations will be funded at a rate of 8% of MTDC.

Modified Total Direct Cost (MTDC) base may exclude: equipment, capital expenditures, charges for patient care, rental costs, tuition remission, scholarships

and fellowships, participant support costs and the portion of each subaward in excess of $25,000. 19

Pre-award: Preparing, Negotiating and Executing Subawards

Post-awardPre-award



Preparing, Negotiating and

Executing Subawards






20

Principal Investigator(PI)

• Determines frequency and scope of progress reports (but no less frequent than is required by Yale’s sponsor) and informs OSP Pre-award to insert this information into subaward

• Reviews draft subaward


• Works with OSP to help resolve subrecipient issues

• Works in collaboration with PI to review draft subaward

• Obtains from subrecipient all remaining required information, documents and certifications, which may include: IRB/IACUC protocol approval; certification that the sub adopted its own PHS FCOI policy; F&A Rate Agreement


• Verifies subrecipient compliance with sponsor/Yale requirements

• Conducts a risk assessment to determine risk of doing business with subrecipient

• Identifies special terms and conditions, if appropriate, to mitigate risk of working with subrecipient

• Prepares, negotiates, executes subawards

• Completes subaward set up in IRES and in Workday

Preparing, Negotiating and Executing Subawards: Roles & Responsibilities

21


Before issuing a subaward…

▪ Supplier setup for a new subrecipient

For purposes of award setup and payment in Yale systems, a subrecipient is referred to as a Supplier.

– DBO creates a new Supplier in Workday. Be sure to use Spend Category 217 (Subaward

Expense) when setting up a subrecipient Supplier in Workday.

– DBO obtains completed W-8Ben and T-100 if the subrecipient is a foreign entity and

uploads the forms to Workday.

– Vendor Compliance Unit (VCU) reviews and approves Supplier set up in Workday. VCU

checks for suspension and debarment. A debarment flag will prevent set up of a new

Supplier. VCU will contact the Director of Export Controls in OSP in such situations.

22

Preparing, Negotiating and Executing Subawards (continued)

Before issuing a subaward… (continued)

▪ OSP performs a risk assessment of the subrecipient

– If a subrecipient is classified as high risk, OSP works in collaboration with the PI and DBO to develop a risk mitigation plan in consultation with the University Research Compliance Officer as warranted.

▪ OSP prepares appropriate subaward agreement based on Yale’s award and sends it to the DBO and PI for review

▪ The DBO and PI should pay particular attention to the following terms and conditions (any suggested changes requires OSP approval)

– Technical/ program reporting requirements

– Period of performance and termination

– Financial, billing, and payment

– Ownership of intellectual property and data

– Special terms and conditions to mitigate risk

23

Preparing, Negotiating, and Executing Subawards

Subaward Negotiations

▪ It is not uncommon for subrecipients to have questions or request changes to a

subaward.

– Common questions or negotiation issues include:

• Reporting requirements

• Financial terms and conditions

• Intellectual property rights

• Indemnification/Liability

▪ OSP negotiates the subaward on behalf of the University.

– If a subrecipient contacts the DBO with these questions, refer them to OSP

24

Pre-award: Subaward Setup Process

Post-awardPre-award









25


▪ OSP Responsibilities

– Uploads a copy of the fully executed subaward into IRES PT (Proposal Tracking) module

– Maintains subaward in Workday by ensuring Supplier Contract is linked to subaward

Grant Line (GR)

– Emails the DBO and PI the following:

• Copy of the fully executed subaward agreement, and confirms that Workday has been updated

26

Subaward Setup Process (continued)

▪ DBO action upon receipt of the fully executed subaward

– Review the following information (derived from the subaward and Workday) to ensure

accuracy and inclusion:

• Supplier Name (subrecipient name)

• Subaward Amount

• Direct Cost burden limit

• Subaward Start Date

• Subaward end Date

• Subaward Number (GR # Plus CON #)

27

Post-award: Processing Subaward Invoices

Post-awardPre-award









28


• Reviews and approves invoices (expenditure categories and amounts should be consistent with technical/progress reports and requirements of the subaward)

• Assists in the resolution of invoice issues

• Notifies OSP of any performance issues, to add/reduce funding, extend performance period or terminate the subaward


• Reviews and approves invoices for allowability and compliance with the terms and conditions of the subaward

• Assists PI in reviewing invoices and determining if payments are appropriate for the work performed vis a vis the subrecipient’s budget and SOW

• Approves invoices timely, retains copies for departmental records (includes W-8 or T-100 for foreign subrecipients)


• Resolves Financial questions related to invoices

• Receives subaward closeout information and deobligates commitments

Processing Subrecipient Invoices: Roles & Responsibilities

29


▪ DBO/PI Review and Approval of Invoices

2 CFR Part 200 requires the payment of subaward invoices issued under Federal awards to be made within 30 calendar days after receipt of the billing, unless the billing is believed to be improper.

– Verify that a signed and fully executed copy of the subaward was setup

– Ensure the subrecipient invoices include the following:

• Subaward name

• Date of invoice

• Invoice number or reference

• Period of performance covered by invoice

• Expenditures by major category in sufficient detail to enable comparison to project budget

• Current period costs column

• Cumulative period costs column

• Subaward invoice contact person

• Certification of expenses by subrecipient fiscal officer that costs conform to theconditions and support the performance of work by the subrecipient

30

Processing Subrecipient Invoices

▪ DBO/PI Review and Approval of Invoices (continued)

– Subrecipient invoices are sent to appropriate individuals in the Department Business Offices (DBOs) based on assigned Workday roles:

DBO Subaward Invoice Approvers: receive invoice transactions in their Workday In-boxes

DBO Approvers: review, approve, and route the invoice to the PI for his/her approval

– PI and DBO ensure that the charges represented on the invoice:

• Are reasonable based upon the technical progress of the project

• Are allowable, adheres to the budget and SOW, and complies with the terms and conditions of the subaward

• Contain sufficient information to determine the allowability of the cost

– If any charges appearing on the invoice are questionable, the DBO should:

• Contact the subrecipient for an explanation of the questionable charges

• And/or ask for a revised invoice, or for backup documentation

– If the work being performed is not commensurate with the invoice categories and amounts, the DBO should contact OSP for guidance

31

Processing Subrecipient Invoices

▪ DBO/PI Review and Approval of Invoices (continued)

– PI, who has knowledge of the project’s technical progress, is required to approve each invoice.

– If the PI decides not to approve a subrecipient invoice, the DBO and OSP should be contacted as

soon as possible.

– DBO reviews the invoice for adherence to the budget and terms and conditions of the subaward.

– DBO approval in Workday indicates that a review of the invoice against the budget has taken place.

– Invoice contains the following certification language as prescribed by 2 CFR § 200.415(a):

“By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and

accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in

the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information,

or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false

statements, false claims or otherwise.”

U.S. Code Title 18, Section 1001 and Title 31, Sections 3729-3730 and 3801-3812.

32

Processing Subrecipient Invoices (continued)

▪ Reasons for delays in invoice processing:

– No subaward number referenced

– Invalid subaward reference number

– Supplier contract and or subaward grant line expired

– Wrong Supplier name

– Incorrect subaward spend category

– Invoice routed to incorrect DBO

All subaward invoices received in the DBO’s In-box must be cleared in a timely fashion.

All Federally-backed subaward invoices in proper form under 2 CFR § 200.305(b)(3) should be paid within 30 days of receipt.

33

Post-award: Subrecipient Monitoring

Post-awardPre-award









34


▪ What is subrecipient monitoring?

– Steps taken to ensure that the subrecipient conducts the research appropriately and

expenses incurred are in compliance with the terms and conditions of the subaward.

▪ Why is subrecipient monitoring important?

– Ensures compliance with the prime award

– Ensures compliance with the terms and conditions of the subaward

– Ensures compliance with 2 CFR Part 200 requirements

for federal awards

– Supports Yale’s compliance with the Federal Funding Accountability

and Transparency Act (FFATA)

35

Subrecipient Monitoring (continued)

▪ Who has a role in the subrecipient monitoring process?

Subrecipient monitoring is multifaceted and requires the involvement of the PI, DBO, and OSP

PI

Reviews of technical/progress reports and invoices and identifies concerns.

DBO

Reviews invoices and requests clarification of questionable charges.

OSP

Conducts risk assessments, develops risk mitigation plans and ensures plans are executed.

Conducts desk reviews of invoices, and ensures plans are executed.

36

Test Your Knowledge #2

Subrecipient Monitoring Questions: True or False?

▪ Subrecipient monitoring is only performed by OSP?

– True or False?Monitoring is also performed by the PI and DBO.

▪ The PI’s review and approval of invoices is just a formality.

– True or False?The PI’s approval acknowledges review of progress reports and/or satisfactory performance by the subrecipient.

▪ It is the subrecipient’s sole responsibility to ensure all invoiced costs are allowable. Yale just processes the invoice forpayment.

– True or False?Yale, as prime recipient of the award, is ultimately responsible for the subrecipient. The DBO should review invoices carefully to ensure all costs are allowable.

▪ It is Yale’s responsibility to ensure subrecipients are complying with terms and conditions of the subaward.

– True or False?The University has responsibility throughout the life of the award to ensure awarded funds are used in compliance with the terms of the award and that performance goals are met.

▪ Yale provides a higher level of monitoring for high risk subrecipients than it does for lower risk subrecipients?

– Answer: TrueThe frequency and monitoring strategies of the subrecipient are based on the risk assessment and management plan of the organization. 38

Subrecipient Monitoring Answers: True or False?

▪ Subrecipient monitoring is only performed by OSP?

– Answer: FalseMonitoring is also performed by the PI and DBO.

▪ The PI’s review and approval of invoices is just a formality.

– Answer: FalseThe PI’s approval acknowledges review of progress reports and/or satisfactory performance by the subrecipient.

▪ It is the subrecipient’s sole responsibility to ensure all invoiced costs are allowable. Yale just processes the invoice forpayment.

– Answer: FalseYale, as prime recipient of the award, is ultimately responsible for the subrecipient. The DBO should review invoices carefully to ensure all costs are allowable.

▪ It is Yale’s responsibility to ensure subrecipients are complying with terms and conditions of the subaward.

– Answer: TrueThe University has responsibility throughout the life of the award to ensure awarded funds are used in compliance with the terms of the award and that performance goals are met.

▪ Yale provides a higher level of monitoring for high risk subrecipients than it does for lower risk subrecipients?

– Answer: TrueThe frequency and monitoring strategies of the subrecipient are based on the risk assessment and management plan of the organization. 39

Post-award: Closeout of Subawards

Post-awardPre-award









40

Subaward Closeout Requirements

Item Responsibility Action/Required Documentation

Deliverables Yale’s PI▪ Receipt of Technical/Progress Reports

▪ Receipt of Invention Reports and any other non-financial reports

Final InvoiceDepartment

Administrator/PI

▪ Verify all deliverables received

▪ Verify all subaward costs are reported on FSR (Financial Status Report)

▪ Approve and submit FSR and Subaward Reconciliation form to your OSP accountant, which acknowledges all subaward invoices and deliverables have been received and all subrecipient invoices have been included and are accounted for.

▪ All cost sharing requirements are met

41

Subaward/Award Closeout Timeline

When Action

60 days before subaward end dateIf the end date of the subaward comports with the end date of Yale’s award, the PI and DBO should evaluate if a no cost extension (NCE) is necessary for Yale and the subrecipient.

45 – 60 days after subaward end dateDepartment receives all required reports and final invoice for approval of the PI and DBO for processing and payment.

60 - 70 days after subaward end dateReconcile award and subaward invoices.Prepare the Subaward Reconciliation Form and submit it to OSP with signed Financial Status Report.

70 - 90 days past award expirationOSP reviews, certifies, and submits final financial report to sponsor, as well as any other reports or Contract Release Forms (federal contracts only), as appropriate.

After all award/subaward reporting completed OSP initiates award closeout process.

Closeout timelines may vary depending on the requirements of the sponsor (i.e., Federal pass-through awards,

state awards, and some non-federal sponsors require final reports within 60 or 45 days after award expiration).42

http://your.yale.edu/policies-procedures/forms/subaward-reconciliation-form

Post-award: Subrecipient Records Retention

Post-awardPre-award








Subrecipient Records

Retention

43

Retention of Subrecipient Records

▪ How long should award records and documentation be retained by the DBO?

– Subaward documentation must be retained for the same period as Yale’s award.

• State contracts – Usually 3 years from the date of the final payment under the prime contract,

unless otherwise stated in the contract. For example, Connecticut Stem Cell awards have a 5

year record retention period.

– Most federal and private sponsors require a retention period of 3 years from the date of

submission of the final expenditure report, unless the terms and conditions of the award

state otherwise.

Office of General Counsel - Yale Record Retention Schedule

Yale University Retention of University Financial Records Policy 1105 44

http://ogc.yale.edu/sites/default/files/Schedule2011-10-04_0.xls

http://your.yale.edu/policies-procedures/policies/1105-retention-university-financial-records

Course Takeaways

✓ A subrecipient is not the same as a Vendor

✓ Vendor relationships are processed through Procurement.

✓ All subrecipient proposals must include a completed SIC or LOI form (as appropriate),

Scope of Work, budget and budget justification, and any other sponsor requirements

prior to submitting the proposal to the sponsor.

✓ Subrecipient invoices must be approved by the PI and DBO before payment is made.

✓ All parties (PI, DBO, and OSP) play a role in the subrecipient/subaward process and

subrecipient monitoring.

✓ If a subrecipient is not performing, contact OSP. Subawards can be

terminated for non-performance and non-compliance.

45

Contact Information: Subaward Management

46

Robert Prentiss

Sr. Financial Analyst

203-785-3174

[email protected]

Mahawa Kourouma

Subaward Manager

203-432-3380

[email protected]

Jennifer Hayek

Subaward Manager

203-737-1327

[email protected]

Jeanette Culbreath

Subaward Manager

203-785-7320

[email protected]

Beth Kingsley

Associate Director

203-737-1103

[email protected]

Melissa Norton

Subaward Manager

203-785-3084

[email protected]

mailto:[email protected]






In order to receive credit for this course, you must take and pass the online quiz.

Your quiz scores are automatically recorded on your TMS record.

Take the Online Quiz: 10 questions, multiple choice.

Continue to the next slide to see additional resources →

Subrecipient Basics and Monitoring Quiz

47

http://assessment-module.yale.edu/research-administration/subrecipient-basics-quiz

Resources

Contact

▪ OSP Contacts by Department

– https://your.yale.edu/policies-procedures/other/osp-portfolio-contacts-departments

Proposal Preparation

▪ Transmittal Summary (TranSum) Form

– http://your.yale.edu/policies-procedures/forms/1304-fr03-transmittal-summary-tran-sum-form

▪ List of PHS and PHS-like agencies (for COI purposes)

– http://your.yale.edu/research-support/conflict-interest/information-revised-phs-coi-regulations

Subaward Set-Up

▪ 1307 PR01 Establishing Subrecipients Associated with Sponsored Programs

– https://your.yale.edu/policies-procedures/procedures/1307-pr01-establishing-subrecipients-associated-sponsored-programs

▪ W-8Ben and T-100 form for foreign subrecipients

– https://your.yale.edu/policies-procedures/forms/3205-fr05a-irs-form-w-8ben-e-certificate-status-beneficial-owner-united

– https://your.yale.edu/policies-procedures/forms/3415-fr02-exemption-withholding-compensation-independent-and-certain

– http://www.irs.gov/pub/irs-pdf/fw8ben.pdf

48

https://your.yale.edu/policies-procedures/other/osp-portfolio-contacts-departments

http://your.yale.edu/policies-procedures/forms/1304-fr03-transmittal-summary-tran-sum-form

http://your.yale.edu/research-support/conflict-interest/information-revised-phs-coi-regulations


https://your.yale.edu/policies-procedures/forms/3205-fr05a-irs-form-w-8ben-e-certificate-status-beneficial-owner-united

https://your.yale.edu/policies-procedures/forms/3415-fr02-exemption-withholding-compensation-independent-and-certain

http://www.irs.gov/pub/irs-pdf/fw8ben.pdf

Resources (continued)

Supplier Information Guidance

▪ Contact information

– http://your.yale.edu/work-yale/finance-and-business-operations/procurement/vendor-information

▪ Consultant Contracts Information

– http://your.yale.edu/work-yale/finance-and-business-operations/procurement/vendor-information/consultants-or-professional

Federal Regulations

– 2 CFR Part 200: Uniform Guidancehttp://www.ecfr.gov/cgi-bin/text-idx?SID=15d5184c2810c3eef54cd7109663b443&node=pt2.1.200&rgn=div5

▪ Federal Acquisition Regulations (FAR): for contractshttps://acquisition.gov/far/

University Policy and Procedures

▪ Form 1304 FR.03A - Subrecipient Information and Compliance (SIC) Form

– http://your.yale.edu/policies-procedures/forms/1304-fr03-app-subrecipient-information-and-compliance-form

▪ Procedure 1307 PR.01 - Establishing Subrecipients Associated with Sponsored Programs

– https://your.yale.edu/policies-procedures/procedures/1307-pr01-establishing-subrecipients-associated-sponsored-programs

▪ Policy 1307 – Subrecipient- Establishing, Managing and Monitoring

– https://your.yale.edu/policies-procedures/policies/1307-subrecipient-establishing-managing-and-monitoring

▪ Policy 3210 - Consultants and Professional Services Agreements

– http://your.yale.edu/policies-procedures/policies/3210-professional-services-and-consulting

49

http://your.yale.edu/work-yale/finance-and-business-operations/procurement/vendor-information

http://your.yale.edu/work-yale/finance-and-business-operations/procurement/vendor-information/consultants-or-professional

http://www.ecfr.gov/cgi-bin/text-idx?SID=15d5184c2810c3eef54cd7109663b443&node=pt2.1.200&rgn=div5

https://acquisition.gov/far/

http://your.yale.edu/policies-procedures/forms/1304-fr03-app-subrecipient-information-and-compliance-form


http://your.yale.edu/policies-procedures/policies/3210-professional-services-and-consulting

Questions

Email questions to: [email protected] will receive a response within 2 business days.

50


In order to receive credit for this course, you must take and pass the online quiz.

Your quiz scores are automatically recorded on your TMS record.

Take the Online Quiz: 10 questions, multiple choice.

Subrecipient Basics and Monitoring Quiz instructions

51

http://assessment-module.yale.edu/research-administration/subrecipient-basics-quiz