Second Performance Site for Federal Clinical Trial Doug Wilkerson 21 Mar 2001 09:02 EST

I am posting the question below as a favor to a non-subscriber.

Doug Wilkerson

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I was recently asked a question about the accounting treatment of certain clinical trials and would appreciate any guidance you could provide in this regard.

The question is centered around federally-funded trials where one institution was the "primary" and a second institiution receives a portion of the funding as a sort of capitation award (i.e. so much per patient).  Should the second institution treat these funds as federal funds and should this be included in the A-133?

With subawarded funds, they typically carry all the characteristics of the award, assuming that everything would have been flowed down.  However, this might also be treated as a customer-vendor relationship and purchased services.

A view from one person is that since there wasn't a sum certain, and these were capitation awards, it didn't qualify as a "grant", even though the funds were coming from a grant to another institution.

I am particularly interested in knowing how other institutions treat this type of agreement.  Do you have criteria to make a determination re: whether this is federal funding or purchased services?  When would you include this in its A-133 report?
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Doug Wilkerson, Ph.D.              Phone:   (419) 383-4252
Assoc. Vice Pres. for Research  Fax:     (419) 383-4262
Professor of Pharmacology         E-mail:   xxxxxx@mco.edu
Research & Grants Admin.          Web: www.mco.edu/research
Block Health Sci. Bldg., Rm. 148
3035 Arlington Ave.
Toledo, OH 43614-5804

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