Paragraph 4. Policy (of the letter from Alice M. Rivlin, Director addressed
to Heads of Executive Departments and Establishments found at
http://www.whitehouse.gov/WH/EOP/OMB/html/circulars/a133/a133.html), "This
Circular [A-133] does not apply to non-U.S. based entities expending
Federal awards received either directly as a recipient or indirectly as a
subrecipient." Since A-133 does not apply, we generally incorporate the
following T&C's into our foreign subrecipient agreements:

A.      RETENTION OF RECORDS The Subcontractor shall maintain full and complete
records which directly pertain to this Agreement for a period of three (3)
years from the date of final payment or until all litigations, claims, or
audit findings involving the records have been resolved if such claims or
audit is started before the expiration of the said period.
B.      ACCESS TO RECORDS The Subcontractor agrees that the University, the
Federal awarding agency, the Comptroller General of the United States, or
any of their duly authorized representatives, shall have access to any
books, documents, papers and records of the Subcontractor which are
directly pertinent to this Agreement for the purpose of making audits,
examinations, excerpts and transcriptions.
C.      MONITORING The Subcontractor agrees that the University has the right to
monitor the Subcontractor's activities to provide reasonable assurance that
the Subcontractor administers this Agreement in compliance with the
requirements of this Agreement. At the University's discretion, such
monitoring activities may include, but not be limited to, the following:
1.      reviewing any and all reports submitted by the Subcontractor; and/or
2.      performing site visits to the Subcontractor to review programmatic
records and observe operations.

Diana

At 05:49 PM 6/18/98 -0400, you wrote:
>Hello,
>
>This is a first for me and I'm going to be lazy and
>ask your advice instead of trying to think it through with
>my own worn out brain:  I have a proposal which will
>include one subcontract to a university in China and one
>subcontract (or possibly a consultant agreement) with a
>university (or faculty member) in New Zealand.  How do I
>deal with the auditing requirements (A-133)?
>
>Your input and experiences will be greatly appreciated!
>
>Ruth Tallman
>Lehigh University
>xxxxxx@lehigh.edu
>
>