Subawards to Foreign Countries -Reply JIM SIMPSON 19 Jun 1998 11:38 EST


It seems to me that a university in China (which is
undoubtedly not a private institution) would not fall within the
definition of a "non-federal entity" subject to A-133.
Therefore, it would not be considered a subrecipient, and
your institution would not have subrecipient flowdown and
monitoring obligations.

Ditto for the New Zealand university if it's a public institution,
and ditto for an individual faculty member with whom you
have a consultant agreement.  The only possible coverage
I can see is if the NZ university is a nonprofit.

Jim Simpson
General Counsel
Public Health Institute
Berkeley, CA