I am currently negotiating a subaward to a well-established nonprofit
corporation under an NSF grant .  The corporation will not provide audit
access to my institution but is willing to provide audit access to
representatives of the federal government.   The justification for denying
audit access is that salary data and the F&A rate are considered
proprietary information.   My opinion is we need this access in order to
carry out our responsibilities as the grantee.   Over the years I have
never run into trouble around this particular issue when subcontracting to
a wide range of commercial, nonprofit and educational institutions.

I would very much appreciate hearing any suggestions and the experiences of
others who have run into this issue.

Thanks as always for your good advice.

Michael Pelletier
Assistant Director, Office of Sponsored Programs
Education Development Center, Inc.
(617)618-2227

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