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  • Open Comment Period: June 2 - June 12, 2015

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Comments Aug 1, 2016 2:59 pm

Minor point: other policies use the phrase "cost sharing" instead of "cost share". This policy should be updated to be consistent. Aug 1, 2016 2:59 pm

I agree that there should be some link to the instructions regarding how to set up a subaward, including the forms needed and information about the possible need to clear the subaward with the funding agency (ie. NSF) in advance. I know the "before you begin" and "begin" headings are being used throughout the new layout, but there do seem to be problems as to how they are being applied here. Aug 1, 2016 2:59 pm

I realize that this is a post award process but it would be helpful to have a link to the "preaward" part of the process (ie when and how to set up a subaward on your grant). The policy appears to cover everything but could be improved by removing the titles "before you begin" and "begin" - I don't think they are needed. Also it is helpful if you number stuff rather than make it all bullet points. That way when we call you with a question or need to point something out to our PI's we can reference the correct section. Please make hyperlinks to any forms you reference in the document.

Thanks as always for the opportunity for input. Aug 1, 2016 2:59 pm

A job aid would be nice for determining if the entity should be considered a subrecipient or a contractor. Aug 1, 2016 2:59 pm

I would like to see a subrecipient invoice and monitoring uniform checklist for all campuses. Under 2 CFR 200.204/205 a merit review and risk assessment is required. Are we required to do these if the grantor requires the subrecipient, when we act as a pass-through? Second, are subrecipients subject to the federal or the University's procurement policies? If they are a for-profit entity, do any procurement policies apply? Do subrecipients need to have a conflict of interest policy and do we need to request a copy and keep on file? Can you also add a section regarding fixed awards to subrecipients and the rules that apply. Aug 1, 2016 2:58 pm

The headings “Before you Begin” and “Begin” seem odd to me. It looks to me as if “Before you Begin” generally addresses responsibilities and “Begin” addresses the process. I would suggest omitting these or replacing them with other headings, for example “Responsibilities” and “Procedures.”

The major headings would look better if they were worded to include gerunds, for example “Reviewing and Paying Subrecipient Invoices” rather than “Review and Pay Subrecipient Invoices.” But this may be part of a larger style or format that is being used.

thanks for the opportunity to comment.