Policies & Compliance
PO Numbering System
Revised Subaward Invoice Payment Process to Comply with Uniform Guidance
The major reason for the transition to the electronic subaward invoice processing system was due to the release of Uniform Guidance (2 CFR §200.207, §200.305 and §200.338) in late 2013.
Two of the changes are the mandatory review and retention of programmatic reports required on subawards, and the obligation to pay “proper” subaward invoices within 30 days of receipt. The University needed to make these changes to achieve compliance with these new requirements.
Major Changes to Invoice Approval Process
- Subrecipients no longer send invoices to the principal investigator (PI) and grant administrator.
- Instead, subrecipients will submit invoices to: email@example.com.
- SPA sends the invoice to the PI and GA electronically for review.
- PI is certifying/documenting that they have received and reviewed any required programmatic reports during the period covered by the invoice when approving an invoice.
- SPA monitors to ensure that the invoice is approved (or rejected) by the PI and returned to SPA so that it may be paid within the 30 day window.
Changes to Use of Subrecipient Commitment Forms—FDP Expanded Clearinghouse
The University of Minnesota participates in the national FDP Expanded Clearinghouse, which builds on the previous clearinghouse that the Federal Demonstration Partnership (FDP) built to document institutional adherence to PHS Financial Conflict of Interest (FCOI) regulations. Participants in the clearinghouse will be relying on information posted in online institutional profiles instead of sending and receiving individualized subrecipient commitment forms. 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.
Discontinue completing any subrecipient commitment forms you receive from the other institutions participating in the clearinghouse and sending subrecipient commitment forms to those institutions, either at time of proposal or award. If an institution is not a part of the pilot, continue to do business with them as you have in the past (sending or receiving subrecipient commitment forms if needed.)
If asked to complete a subrecipient commitment form by a participating institution, politely tell the other pilot institution that you are a member of the FDP Expanded Clearinghouse, and ask them to use the information from our profile posted at the link shown below instead of receiving a form from us. If the other school protests, tell Lesley Schmidt Sindberg (firstname.lastname@example.org), SPA's subaward compliance officer, so she can contact the subrecipient on your behalf. Be patient; it will take a while for staff at all pilot schools to be fully aware of the pilot.
At the time of the proposal, continue to collect necessary proposal data from your subrecipients (statements of work, budgets, signed letter of intent, biosketches, current, and pending support, etc.). You may continue to collect just-in-time data as you usually do. Do not, however, ask for any information that is included in that institution's online profile.
Subawards with Fairview
Effective January 1, 2011, the UMN reconfigured its subaward and contracting processes with Fairview Health Services. Laboratory services previously provided by the Collaborative Studies Clinical Laboratory (CSCL) will be provided by the Department of Laboratory Medicine and Pathology’s Advanced Research and Diagnostic Laboratory, as described below.
A contract for professional services will be used in the future to procure personnel services of Fairview Health Services employees such as study coordinators, dieticians, etc., as described below.
Fairview Collaborative Studies Clinical Laboratory Becomes a Medical School Laboratory
Laboratory services that were previously provided by Fairview Health Services CSCL under a subcontract will be provided by a laboratory unit in the University’s Department of Laboratory Medicine and Pathology using an internal service organization (ISO) mechanism. Essentially, all of the personnel presently involved in Fairview Health Services laboratory, the laboratory equipment, and physical space will be available to the University to provide the same services to our project.
Purchases of specific laboratory tests from Fairview Health Services that not offered by the Medical School’s laboratory, or investigational drug dispensing fees, or X-rays, etc., should be obtained through a purchase order.
Contracts for Professional Services Will Replace Fairview Subawards
Sponsored Projects Administration reviewed existing subawards with Fairview Health Services to determine if any of these activities meet the definition of a subaward. Most do not, but rather represent procurement of specific skilled professional services provided by personnel of Fairview Health Services. The University frequently procures professional services from external organizations by means of a contract for professional services.
As a result of this determination, Fairview subawards will no longer be used on sponsored projects unless the collaboration meets the definition of a true subaward activity. A special contract for professional services (CPS) approved by both the University of Minnesota and Fairview Health Services will be used to procure the same services used previously on these projects.