The document outlines the core compliance requirements and administrative expectations for FDP (Federal Demonstration Partnership) subawards involving both domestic and foreign subrecipients. It addresses several key areas relevant to federally funded research collaborations. Regarding conflict of interest (COI), subrecipients must specify whether the prime or their own COI policy applies, confirm its compliance with the applicable Federal Awarding Agency, and commit to timely disclosure and reporting of identified financial conflicts before the use of funds. For research integrity, both domestic and most foreign subrecipients must certify they are not currently debarred or suspended from federal transactions, with exemptions for certain foreign governmental or intergovernmental entities.
The agreement further stipulates that subrecipients must ensure all human or animal subject research receives proper institutional oversight and approval, and costs can only be billed during periods of valid protocol approval. Deliverable requirements are detailed, including submission schedules for technical/progress, invention, property, and completion reports, tailored to fulfill the prime's obligations to federal sponsors. Data sharing provisions require compliance with Federal Awarding Agency policies and approved Data Management/Sharing Plans. Export control language assigns each party responsibility for adhering to US export laws, acknowledging licensing requirements and regulatory limitations, while also incorporating anti-terrorist financing compliance for all disbursed funds. Indemnification clauses limit each party's liability to their own negligence, maintaining clear boundaries of legal responsibility. Overall, the document establishes robust procedural, ethical, and legal frameworks for conducting and managing federally funded subaward research collaborations.
