Very well stated Steve :)

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@HRINET.ORG]On Behalf
Of Stephen Erickson
Sent: Thursday, December 07, 2000 8:47 AM
To: xxxxxx@HRINET.ORG
Subject: Re: Fed mandatory flow-down requirements

The prime awardee in writing the subcontract, in essence, takes on the role
of
the sponsor. Provisions only flow-down in terms of requiring compliance if
they
are mentioned in and agreed to by the subcontractor. It is not really
appropriate to simply mention the prime award in its entirety and say
everything
applies to the subcontractor. Some provisions flow down and some do not. For
instance, let's say you have a prime contract containing the "Inspection of
Records by the Comptroller General" clause. In simply passing that down to
the
subcontractor in the same manner as other clauses, you would be assuming the
role, and in fact superseding the Comptroller General. Furthermore, if you
are
writing the subcontract to a different type of organization, or writing a
fixed
price subcontract under a cost-reimbursement prime, you need to make sure
clauses you include are appropriate to the situation.

Are the rules the same for all agencies?  It is not the agency that matter,
but
rather the principles of subcontracting, and those transcend all sponsors.

Steve

"Rosemary K. Alexander" wrote:

> Do any of you know whether mandatory federal flow-through regulations on
> contracts and subcontracts automatically flow down to subcontractors
whether
> or not the prime awardee remembers to include them in the subcontract -
> either by making a general statement that all terms and conditions of the
> prime award are incorporated or by listing them specifically?
>
> If they do, do they flow down the same for all agencies or are the rules
for
> some agencies different?
>
> Thanks in advance to all for your help.  I don't know what I'd do without
> this listserv.
>
> Rosemary
>
> ****************************************
> Rosemary Alexander
> Assistant Director, Office of Research Administration
> Case Western Reserve University
>
> xxxxxx@po.cwru.edu
> Phone: 216-368-2008
> Fax:  216-368-4679
>
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--
Stephen Erickson, Director
Office of Research Administration
Boston College
McGuinn Hall 600
Chestnut Hill, MA 02467
Telephone: 617-552-3345
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 subscription information and a web-searchable archive, are available
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