Here is something that may help.

The FDP Subawards Guidance Doc working group created an FAQ that says “What are the elements that are required in an invoice for cost reimbursement subawards?” At a minimum, a subrecipient has to include the certification, as well as a subaward # and current and cumulative expenses. In addition, the FAQ includes recommended data elements to be included in an invoice. The FDP also created a sample invoicing template.

The FAQs (take a look at FAQ #2) and template can be found at: http://sites.nationalacademies.org/PGA/fdp/PGA_063626

The working group is in the process of updated these FAQs. Whether you are an FDP member or not, you can use these materials to share with your subrecipients if you are not getting the certification. If you are using the FDP templates, the certification is required per Term and Condition #2 on the facepage.

-------------------------------------------------------

Stephanie F. Scott, M.S., CRA

Communications and Outreach Director

Phone: (212) 854-0606

Cell Phone: (646) 248-8573

Email: xxxxxx@columbia.edu

Website: http://spa.columbia.edu/

Twitter: @steph_f_scott

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Yates, JoAnn
Sent: Tuesday, April 05, 2016 9:18 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Certifications requirements in CFR 200.415

We’ve been asked by the Prime recipient to include that language on our invoices as a sub as well.

JoAnn Yates

Director of Administrative Affairs

Blood Systems Research Institute

270 Masonic Avenue

San Francisco, CA 94118

415-901-0740

Fax: 415-567-5899

http://www.bsrisf.org/

xxxxxx@bloodsystems.org

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Chris Thompson
Sent: Monday, April 04, 2016 7:07 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Certifications requirements in CFR 200.415

There’s no mention that this flows down to sub-recipients. As you are spending the funds (and allocating to sub-recipients) I believe the responsibility lies with your institution to assure all funds are being spent appropriately.

I look forward to being corrected if I’ve interpreted this incorrectly J

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Semyonova-Smith, Elena Y.
Sent: Monday, April 4, 2016 6:40 PM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] Certifications requirements in CFR 200.415

Good afternoon,

We are asked to include on our invoices the following wording from UG 200.415 :

“I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil or administrative penalties for fraud, false statements, false claims or otherwise. (U.S. Code Title 18, Section 1001 and Title 31, Sections 3729–3730 and 3801–3812).” ( http://www.ecfr.gov/cgi-bin/text-idx?SID=ee873e1aa906cf3b0d7474d25be3b5a9&node=2:1.1.2.2.1&rgn=div5#se2.1.200_1415 )

but we are not seeing it on the invoices we are receiving from our subs.

Have others included this? Or how are you interpreting the wording in UG 200.415 to determine that you do not need to include it on your invoices?

Feel free to reply to me directly at xxxxxx@ku.edu

Thank you,

Elena

Elena Semyonova-Smith, CRA
Manager, Post Award Services
KU Office of Research
Youngberg Hall, 2385 Irving Hill Road
Lawrence, KS 66045
(785) 864-7435
xxxxxx@ku.edu

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