Leah,

I don't know of any provision that exempts private companies from  audit....if
so I am petitioning to change Boston College to Boston College Corp.
Seriously, the company, like all federal awardees, is subject to audit (at
least under subgrants or cost-reimbursement subcontracts), but it is not
subject to the audit requirements of A-133.  I would simply insert a clause in
the subcontract saying that the subcontractor agrees to cooperate with an
audit of subcontract related books and records required by your institution or
the federal government, and that such audits may talke place at any time
during period of performance or within three years after your institution's
submission of it's final financial report.

As a general matter (and I don;t know whether  you prime award is a grant or a
contract) you should make sure that the clauses and provisions you flow down
are those designated for commercial organizations and not those for
educational or non-profit organizations.

Please feel free to contact directly if you have any questions about specific
clauses.

Steve

Leah Bevan wrote:

> I am working on a subcontract for a private company which will be issued
> under a prime agreement with DOE.  I understand that all the requirements
> of the prime flow down to any subrecipient.  We as the recipient of the
> prime require subcontractors to provide us with annual audit reports.
>
> Since the subcontractor is a private company and not subject to audit they
> of course do not want to provide a copy.  Over the first budget period (two
> years), their budget will be $1,118,890 which to me is substantial.
>
> Can anyone shine a little light for me?  Is there policy/regulations or
> anything in writing I can reference here dealing with small private
> companies and audits?
>
> Thanks for any help,
> Leah Bevan
> Coordinator of Grants and Contracts
> The University of Tulsa
> 600 South College Avenue
> Tulsa, Oklahoma 74104
> (918) 631-2883
> Fax: (918) 631-2073
>
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--
Stephen Erickson
Director, Office of Research Administration
Boston College
McGuinn Hall 600
Chestnut Hill, MA 02467
Telephone:  617-552-3344
On-Campus Fax:  617-552-0747
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