EXHIBIT D
Subcontractor’s Compliance Requirements
[SUBCONTRACTOR]
Award Name:Amount: $
Award Number:CFDA #:
The federal Office of Management and Budget Circular A-133 requires that awardrecipients subject to the provisions of the circular mustcomply with its audit requirements: Accordingly, please check the appropriate boxes and provide the information requested.
[ ]We have completed our A-133 audit for the fiscal year ending ______.
[ ]The audit disclosed no material instances of noncompliance with federal laws or regulations, or reportable conditions specifically related to the award(s) from Case Western Reserve University (CWRU).
[ ]Exceptions were noted, URL to the audit report is: ______.
[ ]We are not subject to the requirements of A-133 because we are:
[ ]afor-profit organization.
[ ]a non-U.S. based entity.
[ ]other (explain):______.
Although we are not subject to the requirements of A-133, by signing below we are certifying that any and all expenditures have been and will be made in accordance with OMB circular A-21 or the OMB circular that pertains to our type of organization. See the following website for information about the various OMB circulars:
[ ]Upon completion of any on-going A-133 audits, we will notify CWRU of the results, and provide a copy of any noted exceptions.
SUBRECIPIENT’S COMPLIANCE WITH 42CFR50 SUBPART F and 45CFR94[FCOI]
(For Public Health Service Funding)
As an awardee institution, CWRU is responsible for monitoring subrecipient’s compliance with federal regulations on the Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought (42CFR50) and Responsible Prospective Contractors (45CFR94). We need positive assurance that you are in compliance*. Therefore, please check the appropriate boxesand provide any required documents.
[ ] We have implemented a policy on conflicts of interests that complies with 42CFR50 Subpart F, and 45CFR94 (as applicable).
[ ]To the best of our knowledge, all financial disclosures required for investigators participating in this project have been made.
[ ]Prior to our expenditure of any funds under this award, we agree to submit to CWRU any FCOI reports as required under 42CFR50 and 45CFR94. For any FCOIs identified subsequent to the initial report under this award, we will provide to CWRU within 30 days any FCOI reports, as required. (Please submit FCOI reports to the CWRU Conflict of Interests Committee, email: .)
*Entities needing guidance about development of acceptable COI policies should go this link. For more information on the FDP model COI policy, see the Federal Demonstration Partnership webpage:
Signature:______Date:______
Name and Title of Institutional Official:______
Address: ______email:______
Send responses to: Office of Research
Rev 09/2012