This is a touchy matter. Complex in terms of responsibilities and of methodology. My experience has been that a "desk audit" of charges/invoices seems reasonable in most cases. This is made much easier if the subaward is written with a desk audit in mind. Of course the first matter is, "did the sub- produce?" You will have to defer to your PI for this, but you should specifically ask the PI if the work was completed, and was it satisfactory, and document the answer. The budget should be reasonable both in how it is constructed and what local pay rates might be. Creating the subaward should take into consideration the identity and location of the subawardee. A university in a Western society should have systems relatively similar to U.S. practice, but different organization types and non-Western societies may create large differences. A simple flow-down of U.S. regulations is seldom useful. For example, you should spell out some basics like separate accounts, auditable records of time/effort, invoicing requirements and the like. I have dealt with a reputable university in a Western society that did not do either of these, and the matter only came to light when a completely different problem arose. (I was able to get them to do an internal audit sufficient that they certified explicitly to most of the costs and removed some that were improper.) You probably want to specify billing written in English and measured in U.S. dollars, and the standard for conversion, e.g., the exchange rate posted by a major international bank, and the applicable date, e.g., a stated date quite reasonably close prior to the invoice date. You should be absolutely sure that the person who signs the agreement has the authority to do so; you should be able to rely on a clause warranting that the signator is authorized. You should try to get some idea of underlying audit practices and reliability for the recipient. A number of socially driven requirements on U.S. institutions, e.g., EEO, do not apply to foreign subs, but others, e.g., human subjects research requirements do apply (they may have an approved IRB, but your IRB's review may satisfy if the contract specifies non-deviation from the specified research protocol). The agreement should definitely have a termination for cause clause, carefully written to cover deviations from business/administrative requirements as well as from SOW deviations. In areas of significant uncertainty, you may want to issue a series of "tasks", priced by task, and each authorized only on satisfactory completions of the previous, to minimize the risk if things fall through. If the PI travels to, or is familiar with, the subawardee, you will probably want to discuss with him/her quite a bit of this, as the PI may know a lot that you do not about the recipient and the culture. This discussion should start when the proposal is in preparation, so that the "business" parts of the proposal reasonably reflect what you will put in place in the subaward. Seldom will you have the opportunity to have an administrative representative from your institution visit, unless the subaward is quite large. So you have to think things through to put in place things that minimize risk and make a desk audit reasonable. You may want to have some discussions by phone with business representatives of the foreign subawardee to get a "feel" for their practices, and maybe get references to other U.S. institutions they have dealt with, and then do follow up with a call to that U.S. institution! You may even want informal discussions with your prime sponsor's business types; they may have experience relevant to your situation if it falls far from the Western norm. There is no "one-size fits all" solution. Be reasonable, anticipate problems, reduce risk. And find ways to minimize problems for the subrecipient, too; it will be appreciated. Chuck At 12:58 PM 6/24/2004, you wrote: >With the expectation of closer subrecipient monitoring, can anyone share >what plan they have in place for foreign subrecipients? Actual on site >auditing is a high expectation for those subrecipients in the same city, >and we definitely can't go to foreign sites. Although we'd have lots of >volunteers to audit Hawaii, I doubt anyone would go to Tanzania, etc - >so, any plans in place with one foot in reality? > >Thanks! > >Elisa Espinoza Fallows, M.S. > >Research Compliance Manager >The University of Texas Health Science Center at Houston >Phone: (713) 500-3214 Fax: (713) 500-0326 >E-mail: xxxxxx@uth.tmc.edu > > >====================================================================== > Instructions on how to use the RESADM-L Mailing List, including > subscription information and a web-searchable archive, are available > via our web site at http://www.hrinet.org (click on "Listserv Lists") >====================================================================== Herbert B. Chermside, CRA Special Asst. to VP-Research Virginia Commonwealth University PO BOX 980568 Richmond, VA 23298-0568 Voice: 804-827-6036 Fax 804-828-2051 e-mail xxxxxx@vcu.edu ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
