This sounds like something that could be handled as a procurement of services rather than either a subcontract and definitely not a consulting agreement.

Marjorie Forster
Assistant Vice President, Research and
Global Health Initiatives
Office of Research and Development
University of Maryland Baltimore
620 West Lexington Street, Suite 400
Baltimore, MD 21201
410-706-6631
410-706-6630 (fax)
xxxxxx@umaryland.edu<mailto:xxxxxx@umaryland.edu>

On Jul 11, 2014, at 1:46 PM, Jen Donais wrote:

Dear All,
We are trying to evaluate the use of a consulting agreement (vs. a subcontract) for the collection of blood samples under an NIH prime award.  Our PI has proposed a consulting arrangement and both the grants & contracts office and I have some concerns about liability and compliance if we were to use a consulting agreement vs. a subcontract (with full federal terms flowed down).   Our investigator indicates that this is done all the time in her experience at medical institutions and our leadership would like to be sure we are vetting this issue fairly.

Does anyone have experience utilizing a consulting agreement for the collection of blood or tissue samples at a non-contracted collection site?  If so, could you offer some input on how the transaction was structured so as to ensure compliance and mitigate liability?

Many thanks – appreciate the collective brain power!
~jen

*  *  *
Jennifer A. Donais, MPA, CRA
Director
Office of Research Compliance
221 Arnold House
715 North Pleasant Street
University of Massachusetts
Amherst, MA 01003
Phone: (413) 545-5896
Fax: (413) 577-1728
xxxxxx@research.umass.edu<mailto:xxxxxx@research.umass.edu>
https:/www.umass.edu/research

This transmission may contain information that is privileged, confidential and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is STRICTLY PROHIBITED. If you received this transmission in error, please immediately contact the sender and destroy the material in its entirety, whether in electronic or hard copy format. Thank you.

====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner)

A link directly to helpful tips: http://tinyurl.com/resadm-l-help ======================================================================

======================================================================
 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.healthresearch.org (click on the
 "LISTSERV" link in the upper right corner)

 A link directly to helpful tips:  http://tinyurl.com/resadm-l-help
======================================================================