Re: Subcontracting to a foreign entity under an NSF grant Quinn, Bradley L 19 Jun 2000 12:55 EST

I'd pass on whatever I wanted them to comply with.  The contract is between
Mich Tech and the UK organization.  A-133 doesn't apply to "non-US based
entities" for awards they might receive directly or as a subrecipient but
that doesn't preclude our using the guidelines in A-133.  You might even
consider going to the UK and doing your own audit.

-----Original Message-----
From: Mike Gilles [mailto:xxxxxx@MTU.EDU]
Sent: Monday, June 19, 2000 12:49 PM
To: xxxxxx@HRINET.ORG
Subject: Subcontracting to a foreign entity under an NSF grant

I am embarrassed to have to ask this question as I know that it has been
discussed to death in the past, but...  I am writing a subcontract in excess
of $100,000 to a an entity in the UK.  How do we handle flow downs of such
things as A-21 and A-133 requirements?

Mike

--------------------------------------------------------
Mike Gilles <xxxxxx@mtu.edu>
Sponsored Programs Administrator
Research Services
Michigan Technological University
Houghton, MI 49931
Phone (906) 487-2225 Fx. (906) 487-2245
Date: 06/19/00  Time: 12:40:17
--------------------------------------------------------

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