In 2011, the Federal Demonstration Partnership (FDP) created a PHS Financial Conflict of Interest (FCOI) Clearinghouse as a mechanism for FDP member and non-FDP member institutions to document that they had a PHS FCOI compliant policy in place. This repository allowed participants to forego the exchange of thousands of individual transaction-specific documents. As of January 2016, 962 institutions are listed in the FCOI Clearinghouse. The success of this initiative led to the concept of an expanded Clearinghouse that would contain audit, demographic, and fiscal information needed by pass-through entities (PTEs) when they are issuing subawards. The need for a national repository was exacerbated by release of the Uniform Guidance, which expands subaward risk assessment and monitoring obligations. Many institutions created “Subrecipient Commitment Forms” to collect such data, but the proliferation of many different forms collecting mostly similar information has underscored the need for national consistency and a more efficient process.
In 2015, the FDP collected 133 subrecipient commitment forms from its members, and analyzed the data elements to derive a single, common profile that can be broadly used for this purpose. The Expanded Clearinghouse, Phase I, a national repository of posted information, was created as a less burdensome alternative to achieve the stewardship obligations expected in the subaward issuance and oversight process. Cohort 1 launched in March, 2016 and Cohort 2 in August, 2016, and there are currently 79 participants involved in the pilot. (A list of entity profiles and more information on this exciting project is available here.)
Pilot participants from FDP member institutions create entity profiles based on a standard Excel template, and those profiles are certified by an authorized institutional official and posted to the FDP website. Each entity profile contains data about the participating institution, including demographic data, audit or financial questionnaire results, F&A rates, fringe benefit rates, PHS conflict of interest policy status, debarment and suspension status, and other representations and certifications. The FDP is creating an online database for participants to enter and edit their profiles directly in a secure system.
Subsequent phases of the Expanded Clearinghouse may include automated data entry into a database structure from federally available data sources, such as SAM records and the Federal Audit Clearinghouse, or, alternatively, influencing one of those national repositories to record and make publically available the data elements needed by institutions issuing subawards. As the FDP and other organizations work on obtaining regulatory relief from the need to share and monitor audit data among Single Audit recipients, the Expanded Clearinghouse serves as a stop-gap measure to ease the burden of collecting entity information on subrecipients. Information is easily accessible and reliably accurate without the need to send multiple forms back and forth between our peers.
We encourage everyone to use the Clearinghouse even if you aren’t a member of the pilot – information from pilot institutions can be downloaded for anyone’s use, and a copy of the profile template can be downloaded for use at your own institution. Spread the word!