I had the "a subcontract is a subcontract" problem, too.  the arguement
revolved around whether or not collaboratively proposed wprojects had to be
competetively bid by procurement in order that we make a payment.  I
assembled many pages of support to clarify the differentiation you are
seeking, and the head of state purchasing made -- and recorded -- the
decision that the competitiion occurred in the selection of the "team" by
the sponsoring agency, and therefore the collaborative agreement was NOT a
procurement, and therefore our OSPA could issue the "subaward" (explicitly
no longer "subcontract".  If it would help, I'll fax you a chunk of stuff
from which you may glean some arguments.

Chuck

At 09:52 AM 10/8/98 -0500, you wrote:
>We are having a problem with auditors on our collaborative projects.
>The auditors do not see a difference between projects that are
>developed collaboratively by several institutions (working as partners)
>and projects developed by one institution with the intent to subcontract
>once funds are awarded.
>
> We have explained to them that collaborative projects involve partners
>who have worked together to develop the statement of work but the
>sponsor requires one partner to serve as fiscal agent.  Therefore, funds
>for the partners must be disbursed through a subcontract.  However,
>the auditors insist that a subcontract is a subcontract is a subcontract,
>and that we must receive bids before we make an award.
>
>We, obviously, have no desire to go back to a partner and tell them we
>got the funding, but they now have to re-compete in order to receive
>their share.  We have included names of the partners in the contract
>with the sponsor and have even gotten letters from the sponsor
>acknowledging that a partner is part of the project, all to no avail.
>
>How do some of you handle this situation?
>
>Ann Lessem, Ph.D.
>Program Manager
>The Proposal Office
>Texas Engineering Extension Service
>Texas A&M University System
>
Herbert B. Chermside, CRA
Director, Sponsored Programs Administration
Virginia Comonwealth University
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