|
New Subaward Agreements
New subaward agreements will continue to be negotiated and unsigned agreements issued for execution by subrecipients during the transition. SPA will not be able to finalize and countersign such subawards until after Go-Live, given that the assigned Subcontract Number needs to incorporate the EFS PO number. After Go-Live, SPA will establish applicable POs, execute and return fully-signed subaward that have been negotiated during the transition. SPA’s transmittal letters to subrecipients during this time will let subrecipients know that there may be a delay in payment of subaward invoices until late July because of the financial system transition.
Modifications of Ongoing Subaward Agreements
SPA will continue to negotiate and execute amendments and modifications (e.g., adding time and/or money) to existing subawards during the transition and send those to subrecipients. This will be of value to subrecipients who rely on such paperwork to permit subaward costs to be charged at their own institutions. However, any increases in funding or time extensions cannot be reflected in EFS until after Go-Live. This means that payments to subrecipients against any increased amounts will also be held until after Go-Live (see payments section, below).
New Subrecipients
If a subaward will be issued to a new subrecipient, SPA will need to request that a new customer be set up in EFS before establishing the PO; the turnaround time for new customer setup has not yet been established, but is likely to take several days. The subaward instrument will be negotiated as outlined above, but subrecipients will be notified that their finalized subaward may not be able to be issued until mid-July 2008. On a case-by-case basis, and following a written request from the department describing the reason that it is impractical to wait until mid-July for a subaward to be finalized, SPA will issue a subaward agreement carrying a temporary Subaward Number and then modify the agreement to reflect the permanent number in July. While this may resolve any issues about whether a subrecipient can legitimately charge costs, it will not expedite issuance of a subaward payment (since a PO reflecting the correct customer name must be established in the system before payments can be made to the subrecipient.) This option will be exercised only in rare, compelling circumstances.
Payment of Subaward Invoices
PIs and Departments should continue to review and approve invoices and send them to SPA for payment. SPA will add the applicable EFS chart string to the invoice and process it for payment. After Go-Live, SPA will review and approve the invoices, and then send them to AP for payment.
The Grants Policy Committee (GPC) of the US Chief Financial Officers Council held a Stakeholder's Webcast on March 18, 2008 to update the community on the GPC's progress on meeting its strategic plan, the development of the (non-research) Performance Progress Report format and the Federal Funding Transparency and Accountability Act (FFATA) grants sub-award reporting pilot project. As you. will recall from previous updates, the FFATA directs the Office of Management and Budget (OMB) to establish by January 1, 2008, a single comprehensive database of federal contracts and financial assistance awards beginning with FY 2007 funding. In addition, OMB is required to initiate an 18-month pilot program beginning in July 2007 to test the collection and reporting of subcontractors and subgrantees information and, based on the program, begin incorporating that information into the federal spending database by January 2009.
The initial database of federal awards is now accessible at http://www.usaspending.gov/ The data is searchable by a number of fields including contract or assistance agreement; by state; congressional district; and/or organizations.
The subcontractor and subawardee pilot data collections are proceeding, albeit on the assistance side a bit off the scheduled July 2007 date set by FFATA. Andrea Brandon, chair of the Sub-Award Pilot Workgroup, announced that the pilot is scheduled for June 23, 2008 through August 23, 2008. GPC is seeking additional volunteers to participate in the pilot and COGR encourages its members to volunteer. Send an email to GPCwebcast@nsf.gov
The process has been more complicated because of the steps required within the federal government to establish the data elements and regulations to support the final processes. Regulations on the use of the DUNS number and CCR.gov (Central Contractor Registration) system for grant subawardees and related grant terms and conditions have been drafted to be posted for public comment. Regulations implementing the FFATA pilot have been prepared to be posted in May with a 30 day comment period. These regulations will describe who reports, what, when and how to report. Participation in the pilot will allow institutions to help shape the process to make it streamlined and efficient. Pilot participants will include state and local governments, non-profit organizations and tribal entities. Universities will want to be well represented and may bring important challenges to the pilot. GPC needs to test awards with multiple subawardees at multiple tiers. FFATA sets the reporting threshold at $25,000 – if an argument is to be made to change that threshold, examples gathered during the pilot phase will provide important evidence.
The materials from the March 18 GPC webcast can be viewed and reviewed at: http://www.grants.gov/aboutgrants/grants_news.jsp
|
