As stated on the FDP website, the FDP Subaward Agreement Form may be used by any institution and there is no longer a separate form for use with non-FDP institutions.  My question is this:  Is it appropriate to use the FDP Subaward Agreement Form when the funding agency is a non-FDP member agency?

For example, if I have an award from a federal agency that is not one of the 10 FDP member agencies with an Attachment 2 containing agency specific requirements,  is it appropriate for me to use the FDP Subaward Agreement Form as my subaward document and use the prime award document as my Attachment 2?  Item 11 on the cover page of the FDP Form is the item of uncertainty.  It states, "Subrecipient also assures that it will comply with applicable statutory and regulatory requirements specified in the Research Terms & Conditions Appendix C found at http://www.nsf.gov/bfa/dias/policy/rtc/appc.pdf."  The FDP website states that Appendix C contains the statutory and regulatory-based requirements applicable to all Federal research agencies so I interpret that to mean it's an appropriate reference for both non-FDP member agencies and FDP member agencies.  Is that a correct interpretation or am I missing something?

I appreciate any insight or opinions you can provide.

Thanks,

Mike Mohatt

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Mike Mohatt, Contract Specialist
Sponsored Programs and Research
Office of Research & Creative Activity
University of Nebraska at Omaha  -  EAB 203
6001 Dodge Street  -  Omaha, NE  68182-0210
(402) 554-2286  -  xxxxxx@unomaha.edu

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