We are going through this with several federal agencies. Apparently, some
agencies feel that the money, although pass-through, comes from the
university not the prime federal agency. The feeling is that the loses its
federal identity by going through the outside agency. In one case, we ran
the subcontract through a third party university. In the other cases, I
have been on the phone with the granting agency to see what agreements they
have in place with the recipient federal agency so that the subcontract can
be structured in a mutually satisfactory manner.
In any case, the process is often long and sometimes tedious.
____________________________________________
Marie F. Smith
Manager of Grants Administration
Institution of Ecosystem Studies
PO Box AB, Route 44A
Millbrook, NY 12545
(914) 677-5343 (phone)
(914) 677-7508 (direct)
(914) 677 5976 (fax)
xxxxxx@ecostudies.org
-----Original Message-----
From: Sarah Cooley [mailto:xxxxxx@ZOO.UVM.EDU]
Sent: Thursday, April 20, 2000 9:55 AM
To: xxxxxx@HRINET.ORG
Subject: subcontracting with a Federal Agency
Hello:
I am seeking input from anyone having experience establishing a subcontract
agreement with a Federal agency. Our institution has received a grant (a
Standard Grant) from USDA CSREES subject to 7 CFR Part 3015, 3017, 3018,
and 3019. The budget in the approved application included dollars to
subcontract for part of the work to be done by USGS. The subcontract
agreement I originally prepared and sent to USGS included the terms and
conditions from the prime grant. USGS wants us to remove the Terms and
Conditions and does not want to sign the Debarment, Suspension,
ineligibility Exclusion for Lower tier transactions. They have provided a
draft of an agreement that leaves out any reference to the prime sponsor.
I found in 7 CFR 3015 (3015.2 specifically) that the the prime award's
provisions do not automatically apply to subgrants with recipents that are
"agencies or instrumentalities of the Federal government..."
Does this mean that the terms and conditions USDA has applied to us do not
have to passed down to USGS as subgrantee?
If not, what, if any, terms and conditions do I need to make a part of the
agreement?
Any experience, advice, opinions, examples would be greatly appreciated.
Please respond directly to:
xxxxxx@zoo.uvm.edu.
Thank You!
Sarah Cooley
Sarah Cooley
Sponsored Programs Administrator
The University of Vermont and State Agricultural College
340 Waterman Building
Burlington, VT 05405-0160
Phone: (802) 656-3360
FAX: (802) 656-1326
email: xxxxxx@zoo.uvm.edu
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