Interesting problem here.  You have an obligation as a recipient of
federal funds to ensure that subawardees use their funds in accordance
to A-21 and 110.  You can't get out of that.  Neither can they.  How
would they do an audit if they were direct recipients?  Do they have to
do an annual A-133 audit (probably do)?  Couldn't you do a desk review
of that looking at the auditor comments?  That's pretty much what we do
with each other when we do subawards with another college.

You could also restructure the relationship so that it is a purchase of
service contract and not a subaward.

I am surprised, though, that a non-profit is acting like this.  Usually
if it's payroll info they want to protect, it isn't to prevent their
competitors from knowing, its an internal privacy issue.  They don't
want their own people knowing what  each other's salaries and benes are.

Good luck.

Greg Schmidt

Michael Pelletier wrote:

>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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