2.3. Subcontractor Oversight
This section deals with the administration of property, either titled to CU or to the sponsor (including Government) property, located at or accountable to a subcontractor of the university. Property control and management at a subcontractor’s facility is a key component in an efficient, professionally administered business.
Initiating a Subcontract
The Principal Investigator (PI) is responsible for initiating any subcontract that is in support of the contract or grant being managed. OCG issues the subcontract that includes the statement of work and the relevant terms and conditions. If the subcontractor is authorized to purchase property, this must be clearly stated in the subcontract from the University of Colorado. OCG subcontract officers assure that all applicable flow-down terms from the prime agreement are included in the subcontract.
Verifying a Subcontractor's Property Control System
The university is required to ensure Government or sponsor owned property in the possession of a subcontractor is used and cared for in accordance with the terms and conditions of the applicable agreement. OCG requires the subcontractor to supply sufficient information to assure this stewardship when executing the subcontract agreement. The subcontractor should provide a copy of their most recent Government Property Management System Analysis (PMSA) and complete a e. If the subcontractor has never received a PMSA and the self- assessment is inconclusive, another method of confirmation is used. Loss, damage or destruction of property under subcontractor control is a liability to the University of Colorado.
Prior Approvals for Acquisition
In situations where sponsor approval is required prior to acquisition by the subcontractor, the subcontractor is required to send a request to OCG. OCG works with the PI and potentially the sponsor to secure approval if not pre-approved and notify the subcontractor in a timely manner. Departments validate the subcontractor invoices against the approved budget to ensure invoices only include approved expenditures.