FDP Pilot Add Additional Institutions & Changes to Use of Subrecipient Commitment Forms
As you may recall, the University of Minnesota is participating in the national FDP Expanded Clearinghouse pilot, which began on March 28. The pilot has been running smoothly and a second cohort of institutions has joined the pilot last week. There are now 78 member institutions currently participating with 127 entity profiles which can be found at: http://sites.nationalacademies.org/PGA/fdp/PGA_171219
This project builds on the previous clearinghouse that the Federal Demonstration Partnership (FDP) built to document institutional adherence to PHS Financial Conflict of Interest (FCOI) regulations. With this pilot, we will be relying on information posted in on-line institutional profiles instead of sending and receiving individualized subrecipient commitment forms as we participate in subawards from and to the other participating pilot institutions. Subrecipient commitment forms typically require completion of institutional information about our F&A rates, fringe benefit rates, audit status, COI policy status, Federalwide Assurance for Human Subjects, etc.
Effective immediately, you should discontinue completing subrecipient commitment forms you receive from the other institutions participating in the pilot including the new institutions recently added, and you should also discontinue sending subrecipient commitment forms to those institutions - either at time of proposal or award. A list of the institutions/campuses participating in the pilot may be found at: http://sites.nationalacademies.org/cs/groups/pgasite/documents/webpage/pga_173303.pdf. If an institution is not a part of the pilot, you should continue to do business as you have in the past (sending or receiving subrecipient commitment forms if needed.) If you have any in-progress subrecipient commitment forms with pilot institutions, please finish those up within the next week.
If you are asked to complete a subrecipient commitment form by a pilot institution, please politely tell the other pilot institution that you are a member of the FDP Expanded Clearinghouse pilot, and to please use the information from our profile posted at the link shown below instead of receiving a form from us. If you continue to get push back from the other school, please let Lesley Schmidt Sindberg SPA's Subaward Compliance Officer know (firstname.lastname@example.org), and she can contact the other school on your behalf. It will take a little while for everyone at all the pilot schools to be fully aware of the pilot, so please be patient as information about the pilot trickles down to all the staff at the other institutions.
At time of proposal, you should continue to collect necessary proposal data from your subrecipients (Statements of Work, Budgets, signatures of SPA office representatives, plus any other documents your proposal requires (biosketches, current and pending support, etc.). You may also continue to collect just-in-time data as you usually do. You should NOT, however, ask for any information that is included in that institution's on-line profile (see link below).
To verify F&A or fringe benefit rates from these subrecipients or to see the names/titles of their key contacts, you should feel free to link to their posted on-line profile at: http://sites.nationalacademies.org/PGA/fdp/PGA_171219. Click on the name of the institution to see their profile. I've attached our Twin Cities one to this email so you can see what a profile looks like. You can download and save an institution's profile or just view it online. Most have links to their audit, F&A or fringe benefit rates embedded within their profile, but a few have sent those documents separately. For those few institutions, you will see hyperlinks to those documents next to the institution's name.
SPA will also continue using these profiles to expedite our federally-mandated risk assessment reviews prior to subaward issuance or modification with these pilot institutions. We are tracking how many subawards we issue that use the new process to assess the time savings of having the profiles available. The initial tracking data is promising but still being analyzed. We will share it with you when available.
Please don't hesitate to let me know if you have any questions.
Lesley Schmidt Sindberg
Subaward Compliance Officer | Sponsored Projects Administration
University of Minnesota