Sponsored Program Compliance

Special Considerations

Small Businesses

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.

Foreign Institutions

• Not all sponsors will support international subrecipients.
• Most federal sponsors will provide a ten percent (10%) indirect cost rate to international sites (NIH only allows an eight percent (8%) 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 budget should be prepared showing both the proposed costs in the country's currency and the converted US dollar value, noting the conversion rate. The subagreement 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, not the currency rate used during the proposal stage. For more information, see Section VIII, Page 24, Post Award Considerations, of the Subagreement Manual.
• Foreign sites may require advance payment in order to conduct the project; this situation should be disclosed immediately to ORPA. For more information, see Section IV F, Page 14, Advance Payments of the Subagreement Manual.
• 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 followed.