RSP 503–05: Subcontracts/Subaward Agreements

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

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”

This policy applies to all subcontracts or subawards issued by ASU under a sponsored project. It is ORSPA’s responsibility 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

The director of the Office for Research and Sponsored Projects Administration (ORSPA) 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.

If the university passes the threshold of receiving more than $25 million in federal funds annually, the Office of Naval Research (ONR) may deem it necessary to conduct a contractor purchasing systems review (CPSR). ORSPA is responsible for coordinating actions to support the review, including any necessary corrective actions, to receive a system approval by ONR.

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