Research and Sponsored Projects Manual (RSP)

Effective: 1/1/1992

Revised: 7/1/2009

RSP 503–05: Subcontracts/Subaward Agreements

Purpose

To assure university compliance with federal, state, and ABOR requirements for subcontracts/subawards

Sources

United States. Office of Management and Budget. OMB Circular A-110, Uniform Administrative Requirement for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, Subpart C, Procurement Standards

United States. Office of Management and Budget. OMB Circular A-133, Audits of States, Local Governments, and Non-Profit Organizations

Code of Federal Acquisition Regulations (FAR) Part 44

Department of Defense FAR Supplement (DFAR) Subpart 244

Arizona Board of Regents Policy Manual - 3-801, “University Procurement Code”

Applicability

This policy applies to all subcontracts or subawards issued by ASU under a sponsored project. It is the responsibility of the Office of Research and Sponsored Projects Administration (ORSPA) to ensure that proposed subcontracts are compliant with applicable federal, state, and ABOR laws, regulations, and statutes. ORSPA will exercise due diligence in the review, evaluation, and selection of subcontracts to make certain that an appropriate and compliant subcontract is awarded

Policy

The ORPSA director and/or his/her designee(s) has the responsibility, on behalf of ASU, to conduct or be involved in all formal negotiations with subcontractors to establish contractual relationships under all sponsored projects. The director’s involvement is intended to assure to the maximum extent practical that the procurement:

1. provides open and free competition
2. does not present a conflict of interest
3. complies with all federal, ABOR, and university statutes, regulations, and policies

   and

4. is properly documented.

ORSPA also has the responsibility to train all ORSPA personnel involved in the preparation, completion, documentation, and monitoring of subcontracts, and to update policies and define procedures when necessary.

ORSPA will include as flowdown provisions all applicable clauses in the ASU award. After signing, ORSPA forwards subcontracts/subawards to Purchasing and Business Services for issuance of a Purchase Order.

As a result of the Contractor Procurement System Review (CPSR) performed by the Office of Naval Research (ONR) during January 29, 2007 through February 2007, ASU has an approved procurement system through February 2, 2010. With the approved system, ASU may enter into certain subcontracts and purchase orders without receiving consent from a Department of Defense (DOD) Contracting Officer, unless specific contractual language stipulates otherwise. ORSPA is responsible for coordinating actions to support the CPSR, including any necessary corrective actions, to receive system approval by ONR.

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