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Re: Federal Acquistion Regulations (FAR) Herbert B. Chermside 11 Feb 2004 13:48 EST

A-110, and the individual agency implementations, discuss subawards and
subrecipients of grants, cooperative agreements and other assistance
Under definitions, see subaward and subrecipient
Note that allowable costs, at ---.27, depend on the business nature of the
subrecipient
Also at ---.51 there are requirements for monitoring subrecipients.
Each major agency will have expanded information on subawards.  NIH and NSF
have good guidelines that should be models.
Generally, subawards are planned for in the application budget.
Subawards are, explicitly NOT procurement.  Because they are entered into
with the knowing approval of the sponsoring agency, they are not subject to
the competitive requirements of the Procurement section ( ---.40ff), but
the good business practices therein should be a guide.
ALWAYS flow down all the regulatory requirements the sponsor placed upon
you, except
a)  contact is with you, not with the agency, and
b)  do not flow down those "expanded authorities" which would allow the
subrecipient to affect your responsibilities to your sponsor without your
knowledge/permission, e.g., automatic/subrecipient no cost extensions or
carry over of funds; require they get your permission.

Don't have FAR ref's for subcontracts under federal contracts, but that
DOES fall precisely under procurement, and the flow-downs must be looked at
on a case by case basis.

Don't let some unknowing auditor get confused and try to tell you that the
regs and procedures for subs are same for federal assistance and for
federal procurement; the difference is HUGE.

Chuck

At 07:51 AM 2/11/2004, you wrote:

>Good Morning, All:
>
>    I need to find a regulation that discusses subcontract/subrecipient
> activities and clauses as they pertain to Federal Grants,  Cooperative
> agreements and contracts.
>
>    Could someone steer me in the right direction to find this information
> in the FAR?
>
>     Thank you very much.
>            Eleanor Cicinsky
>            Temple University
>
>
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Herbert B. Chermside, CRA
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Voice:  804-827-6036
Fax     804-828-2051
e-mail xxxxxx@vcu.edu

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