I can very well understand why your accounting office needs to know the
funding source for all grants and contracts.  That answer determines which
regulations apply for audits.  As much as possible, a good faith effort should
be made by your instituation to determine the ultimate or prime source of
funding.  Simple documentation should suffice.  But if you can't find out
because your funding source is not sure, they you may have no choice but to
document that and hope for the best.  Otherwise, assume all unclear funding is
ultimately federal and apply those regs and guidelines, since in many cases,
they are the most comprehensive and strictest.

Robert J. Kazalski,
University of Massachusetts,
Controllers Office