of Research and Project Administration
SPONSORED PROGRAMS COMPLIANCE
When the small business is a university start-up, or
when a faculty investigator has a significant financial interest in
the small business, conflict of interest may result. Subcontracting
to small businesses in these situations will require a conflict-of-interest
review and management plan prior to entering into a contractual relationship.
- Not all sponsors will support international subrecipients.
- Most federal sponsors will not provide any F&A
costs to international sites (NIH does allow an eight percent indirect
cost rate on total direct costs less equipment).
- Labor laws and payment issues must be explored.
- The UR budget might need to include funds for auditor
and compliance oversight.
- For NIH awards, prior State Department approval must
be obtained for any foreign site.
- Fluctuations in currency exchange rates could cause
budgetary issues. The subcontract will identify a not-to-exceed amount
in U.S. dollars. Invoices and financial reports should reflect the
currency rate in existence at the time the expense is incurred.
- Foreign sites may require advance payment in order
to conduct the project; this situation should be disclosed immediately
- Subrecipient Monitoring: The UR PI will need to maintain
a high level of oversight for programmatic, administrative and regulatory
issues (e.g., human subjects, animal, and biohazard monitoring). It
is the UR's responsibility to clarify and verify that the terms and
conditions as well as regulatory requirements and assurances are being