*The Q&A content from the January MRAM Q&A Follow Up has been updated as of 1/27/21, and replaces the email sent out on 1/26/21. Q4 has been corrected and Q9 and Q10 were added under the China Telecommunications Restrictions section.*
Greetings Colleagues,
The January 14th MRAM materials are published. Q&A here reflect questions raised both during and after our January session and may have been adjusted slightly for clarity.
Fetch the Future - Rethink the Ink
This UW initiative applies only to those departments who are under the jurisdiction of UW Records Management Services. It does not apply to departments under the jurisdiction of UW Medicine Records Management Services.
Q1: Can you speak for a minute about how records will be incorporated into Workday as the source of primary record retention?
A1: Workday is considered the official record holder. There is no need to print from Workday or maintain paper copies of attached records.
Q2: Procard talked about changes to the JPM site. Currently we can only access records for 24 months. Any word on changes to this?
A2: We do not have final confirmation on what the new Finance Transformation landscape will look like. By the end of March, we should have more information. But until we know for sure, and Workday Finance goes live, Procard records should be maintained in your offices. However, they should be maintained electronically—not in paper.
Questions?
email bbenson@uw.edu
website: https://finance.uw.edu/recmgt/home
China Telecommunications Restrictions
Q1: The NDAA legislation states:
“… COVERED TELECOMMUNICATIONS EQUIPMENT OR SERVICES The term ‘‘covered telecommunications equipment or services’’ means any of the following: (A) Telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities). (B) For the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, video surveillance and telecommunications equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities). (C) Telecommunications or video surveillance services provided by such entities or using such equipment. (D) Telecommunications or video surveillance equipment or services produced or provided by an entity that the Secretary of Defense, in consultation with the Director of the National Intelligence or the Director of the Federal Bureau of Investigation, reasonably believes to be an entity owned or controlled by, or otherwise connected to, the government of a covered foreign country.”
What equipment does that cover?
A1: The language used in the legislation and in the FAR and CFR is vague and they have not provided any additional information or clarity. As such, we recommend that you not purchase any items from the restricted companies.
Q2: What do you suggest if your department has a gift from a company like Huawei? Can your department use that money?
A2: All gift budget questions should be directed to Gift Services at giftdata@uw.edu
Q3: Is the UW going to provide standard guidance on reaching out to subawardees? Will subawards be modified to include these new requirements?
A3: Both federal awards and subawards are written to require that recipients (both prime and sub) are subject to all federal regulations at all times. Federal requirements routinely change and recipients are required to comply as those requirements change. There is no requirement or expectation that awards and subawards will be modified to incorporate every change in the federal regulations. Recipients are required to comply with the federal regulations as they are updated. Thus, we will not be modifying individual subawards to include this language.
Q4: Does this restriction apply to all federal purchases and recipients?
A4: Yes as all vendors and recipients that do business with the federal government are subject to this restriction.
Q5: I'm on SAM and it looks like you have to search by entity name. Is there a way to get a list of entities or would you need to look up each individual entity?
A5: SAM is updated on a regular basis so please review SAM for current functionality.
Q6: If I am using restricted equipment from a covered company on a federal award do I need to stop using it now?
A6: Yes, you cannot use equipment from a restricted company.
Q7: Do we need to stop using equipment if it was charged as an F&A cost?
A7: Yes. Because the federal government pays for F&A (via the F&A rate), we cannot use or purchase restricted equipment from a covered company.
Q8: How do I replace any equipment that I can no longer use?
A8: Contact the sponsor and request guidance.
Q9: Is it possible that other telecommunications companies (US based cell phone providers for example) have products that were made by "covered companies"? Would this be considered an unallowable cost, and if so how would we check this?
A9: You would need to contact the company and ask them if they have any equipment from restricted companies in their use. This would also prove good due diligence in the event of an audit. Remember that this restriction applies to all federal awards and purchases (not just the UW) so most US companies have likely eliminated any equipment from the restricted companies.
Q10: Do you have any advice for how to ensure that purchases that are made from Amazon are compliant?
A10: For all such purchases you need to identify the name of the company that produced the item. You then need to check the name of company against the list of restricted companies in SAM.
Resource Links:
PAFC: Restrictions on Telecommunications Equipment
Questions? email gcafco@uw.edu
Addendum on COVID Funding to the Compliance Supplement
Q: Are departments aware of how to appropriately track COVID-related expenses on grants?
A: Units should check with their Dean/VP’s office administrator for unit specific instruction. If their Dean/VP’s office is following OPB guidance without unit specific modifications, they can refer to the UW Academy COVID Expense and Revenue Loss Tracking Guidelines website.
Questions?
About Post Award Fiscal Compliance: email gcafco@uw.edu
About PCA Code tracking of COVID-related expenditures: email opbcovid@uw.edu
Federal Reporting of Outside Research Work
Q1: Could you help us understand how this applies to the foreign Co-Investigators on our international research projects? they are all employed by a foreign institution. Do we actually need to ask everyone we work with for their employment contracts? I'm referring to subawardees who are Co-I's mostly.
A1: Understanding that NIH hasn’t issued guidelines yet, I would not think this will apply to subawardee Key Personnel employment contracts with their home [foreign] institutions. (They should, of course, be reporting all of their Other Support, including Outside Work related to any of their research.) We’ll have to wait and see what NIH says about providing employment contracts for Other Support consisting of employment outside their home institution.
Q2: Will this apply to, for instance, faculty lectureships at foreign institutions?
A2: Understanding that NIH hasn’t issued guidelines yet, we think it probably will.
Q3: If a student is on a grant but is completing (unpaid) research as part of their graduate program would they need to document this?
A3: If the student is listed as Key Personnel on the NIH grant and they are doing foreign Outside Work related to any research they do, then yes – the student should include the Outside Work (and employment contract) in their own Other Support.
Q4 : Is this for foreign entities? What about work for US companies such as Amazon?
A4: Understanding that NIH hasn’t issued guidelines yet, we anticipate this will be a requirement only for foreign Outside Work – not for domestic Outside Work.
Q5 : Is UW considering requiring asking for foreign employment documents adding to eGC1s?
A5: Until NIH issues guidelines, we won’t be making final decisions on internal processes to support compliance.
Q6 : Will this apply only to NIH grants?
A6: We have heard of this requirement only from NIH so far. We don’t know if other federal agencies will follow suit or if this will be a federal-wide requirement.
Q7 : We haven't been including outside work with the Other Support document. Is this limited to foreign-supported outside work or all outside work?
A7: Outside Work that relates to any of a Key Personnel’s research should be included in Other Support – foreign or domestic. Until NIH issues guidelines, there is no need to include employment contracts. We understand that, when NIH begins requiring this documentation, it will only apply to foreign Outside Work.
Resource Links:
Current and Pending or Other Support
Questions?
email: research@uw.edu
GIM 8: Subrecipient Monitoring Updates
Approval of Subaward Invoices
Q1: Who must approve subaward invoices?
A1: Per GIM 2, the PI who is named in the subaward must approve all subward invoices.
Q2: Can someone with delegated authority (as described in GIM 2) approve subaward invoices?
A2: No. The PI named in the subaward invoice must approve.
Q3: Can Co-PI approve invoices?
A3: No. The PI on the subaward must approve the invoices.
Q4: GIM 8 was updated for clarity, will GIM 2 also be updated at this time?
A4: No. GIM 2 already states that PIs must approve subaward invoices. GIM 8 was updated to ensure clear consistency with GIM 2.
Q5: What if a PI is unavailable to approve a subaward invoice?
A5: As PIs are responsible for the award they should be available for timely review of award expenditures and other award requirements. In the event a PI is not available to approve an invoice within the payment time frame, the dean or chair can approve the invoice as long as they have either first-hand knowledge or suitable means of verifying the work being invoiced was provided (for example an email from a co-PI or someone else with firsthand knowledge).
Q6: What if someone with delegated authority has approved in the past? Do we need to get approval from the PI after the fact?
A6: Yes. If you were confused by the previous language and did not have the PI approve subaward invoices, it is worthwhile documenting approval after the fact.
Q7: How far back do I need to go?
A7: The UW policy that all subaward invoices must be approved by PI’s has been in place for some time under GIM 2. If an auditor were to come review your records, they would want to see that all subaward invoices have been approved by the PI. You would need to go back as far as whatever is subject to an audit and the WA state policy is that we retain records for an award for six years after the end date of the Award (for the entire Award period). Example: an award that started on 1 January 2015 and ended on 31 December 2020, all award records are subject to audit (and need to be retained) until 31 December 2026.
Questions
About Subawards? email ospsubs@uw.edu
About Post Award Fiscal Compliance? email gcafco@uw.edu
PI Approval & Going Paperless
Q1: In light of a paperless and working off site environment how does a PI provide approval?
A1: There are a couple of options:
- Approval is obtained via e-mail and the e-mail is electronically saved or scanned.
- The subaward invoice itself can be signed and then scanned (scanned documents can be uploaded into ARIBA).
- Docusign can also be used for approval. Departments would need to contact UWIT for a DocuSign account, which is free.
Q2: If obtaining PI approval via e-mail is acceptable does it mean that the PI must attach a copy of the invoice with their approval?
A2: The PI’s approval must be linked to the invoice that is being approved. This can be done via e-mail in two ways:
- The PI attaches a copy of the invoice with their approval.
- There is information in the e-mail that identifies the specific invoice that the PI is approving. The request for approval and approve e-mail exchange would include the name of the subrecipient, the invoice period, invoice amount, and any numbering or other information used to identify an individual invoice.
Questions?
About Post Award Fiscal Compliance? email gcafco@uw.edu
Thank you,
MRAM