Hi Carolyn,
You are not wrong to be concerned.
At the end date of the subaward PoP, the project falls out from under contract. Carry-over is fabulous as long as the project is under contract, but it is completely useless if the project is not under contract.
In a way, I guess the prime awardee is correct. You *can* chose to incur costs on exposure, but the downside is the risk of being left with a deficit to cover if the amendment to fund the next PoP is not successfully placed for any reason. It’s a gamble – a real gamble with real money belonging to your institution.
Pragmatic Approach: I would inquiry as to whether or not the prime awardee has in-hand its NoGA or not. If it does then perhaps it might float you a copy to justify your institution doing work “at risk” or “on exposure.” Many institutions have significant lag times in contracting; this reality is not a secret. Given that the risk of being left holding the bag is extremely-low in this scenario, I would probably approve continuing the project unless there was something else wonky going on. I would put a note on my calendar in x amount of weeks to ensure that the funding amendment was now in place or send the PI a note to discuss halting work. The x equals your institution’s tolerance for the monies at risk and the burn rate on the project, etc. (So … if the project was going to burn 50% of the cost in the first month then I might change my own mind about supporting continuance of the project.)
On the other hand, if the prime awardee does *not* have its NoGA in-hand then I would say no thank you and ... head to a slot machine instead.
With kind regards, Madison
Madison Gray, J.D.*, C.R.A., C.C.R.P.
Senior Assistant Director
Office of Contract & Research Administration (OCRA)
Vanderbilt University
email: xxxxxx@vanderbilt.edu
phone: 615-343-1374
*Not legal counsel for Vanderbilt University. The Office of the General Counsel is the only authorized legal counsel for Vanderbilt University.
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From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Carolyn Elliott-Farino
Sent: Friday, August 10, 2012 9:47 AM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] question about FDP template
I need some help in interpreting the FDP research subaward agreement, please.
There is a subaward period of performance:
Subaward Period of Performance:
Budget Period: From: To:
And an estimated project period:
Estimated Project Period (if incrementally funded):
From: To:
What do these dates mean to you? If the period of performance ends July 31, 2012, but the estimated project period goes until July 31, 2015, would you allow spending after July 31, 2012? We are being told by the prime that although the period of performance is over, because we have automatic carry-over and the estimated project period is in the future (2015), we can still spend. I have never seen this situation before, and when I issue a subaward, I don’t expect the subrecipient to spend beyond the budget period/period of performance. If I am wrong about this, I need to know!
Thanks mucho.
Carolyn Elliott-Farino
Kennesaw State University
770.423.6381
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