Research and Sponsored Projects Manual (RSP)

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Effective: 1/1/1992

Revised: 8/2/2010

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RSP 503–05: Subcontracts/Subaward Agreements

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

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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”

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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/subawards to make certain that an appropriate and compliant subcontract/subaward is awarded

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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/subawardees 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


  4. is properly documented.

ORSPA will determine whether prior approval is required to initiate or amend a subcontract/subaward, based on sponsor terms and conditions. ORSPA will include, as flow-down provisions, all applicable clauses in the ASU award. Subcontract/subaward agreements are obligated using the ASU financial system in place upon agreement execution.

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