The prime awardee should never pass on FDP conditions to a non-FDP
institution.  The basic rule in all this is that the subawardee should
be given terms nad conditions that fit the type of  subawardee
(university, company, FDP, non-FDP, etc) and the nature of the work
being done by the subawardee (research, services, etc.)  In the case you
desccribe, I would either attach the non-FDP terms and conditions to the
subaward or refer to them in the subaward. You should also make the
appropriate changes to specific provisions (e.g. "references to the
government shall mean prime awardee") -- this would go in the section of
the subaward in which you are referring to the terms and conditions that
are being passed through.

Steve

Debbie Smith wrote:

>If a prime grantee is an FDP participant, and a subgrantee is not, does the
>subcontract agreement need to include anything about that situation?
>
>Generally, the subcontract includes a reference to "all the terms and
>conditions" of the prime grant--but if the sub isn't an FDP participant and
>the grant references FDP, what should you do?  Do you just ignore it, or
>insert something that says "except that subcontractor is not an FDP
>participant"?
>
>Thanks!
>
>Debbie Smith
>
>Deborah (Debbie) L. Smith, Ed.D.
>Director, Research Administration
>UT Health Science Center
>8 So. Dunlap, Suite C-109
>Memphis, TN  38163
>(901) 448-4823
>(901) 448-7600 fax
>xxxxxx@utmem.edu
>
>
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--
Stephen Erickson, Director
Research Compliance and Intellectual Property Management
Boston College, McGuinn Hall 221
Chestnut Hill, MA 02467
Telephone: 617-552-3345
Fax to my computer:  413-895-8328

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