Our accounting office has just informed me that they need to know the
ultimate source of funding on all grants and contracts (for audit purposes)
even when the award document doesn't specify.     A few of our faculty
members get small amounts of funding to support aspects of their research
from private organizations such as lake associations and from communities,
state government,  and other public institutions.  Sometimes these
agreements reference the prime sponsor and flow-down grant requirements; in
other cases the agreement is basically a scope of work with no mention of
compliance requirements or the source of funding for the project.

Are we responsible for ascertaining what the ultimate source of the funding
is? And if so, do we have to document how we know what the source is? Do we
have to comply with federal agency requirements that haven't been
incorporated into the funding agreement?   In one case that's pending the
small organization has leftover grant funds from a grant that a state gave
them; they plan to use these funds to pay for an agreement with us; it's
possible that the ultimate source of the state grant was federal funding to
the state -- do we have to track down this ultimate source before we can
accept this agreement?

Any light that anyone can shed on this matter would be appreciated.

Franci Farnsworth

Frances Vinal Farnsworth
Coordinator of Sponsored Research
Grants Office - Forest Hall
Middlebury College
Middlebury, VT  05753

Tel:  802-388-3711 x5889
Fax:  802-388-6436
email:  xxxxxx@mail.middlebury.edu