Sub-Award Accounting

Many international partners receive funds through the subaward process. Many of these same institutions partner with several funding mediators in the United States and Europe, each with its own accounting practices (closely aligned with NIH accounting standards).


Department of Treasury keeps a list of sanctioned institutions that cannot receive funds from US sources. Wire transfer funds are an allowable direct expense, but should be budgeted in the subaward contract. UC Campus Offices of Contracts and Grants have the capability to run a list for sanctioned individuals. This is a prudent measure to take when contracting foreign nationals.

Exchange Rates

Exchange rates will vary over time, and inflation may be an issue. Campus Controller’s Offices are responsible for releasing funds to subawards. Mechanisms to pay for goods and services have to be verifiable. You will need invoices, and the subaward must be audited annually by an outside accounting firm. Determine if the audit can be paid with F&A (indirect) funds.

Cash Funds

Keeping a pile of money to pay people is considered non-standard accounting practices. It is very important that the payment mechanism be auditable. There is a mandatory online training for UC personnnel handling cash.

Paying Human Subjects

Reimbursement to research participants is subject to IRB requirements and the regulations of the host country. The payment to a subject cannot be deemed enticing, or sway their decision to participate, merely redeem the inconvenience of participation. That means that local conditions will determine what is appropriate. The best course of action will be to work with the local IRB to determine what is customary locally.

Assets Custodian

If the original funding source is set up as a subaward, you avoid the complications of capital assets controls. If you have UC owned property abroad, you will have to account for it annually in an inventory


There are many issues that arise with staffing a project. Much will depend on who you are partnered with, and what your legal status is within your host country.

Depending on your funding, you may be a business, in which case all the necessities of business ownership apply, including licensing requirements, staffing (laws and benefits) and business insurance. Alternatively, if your funding is dispersed through a UC campus, your staff may be entitled to University protections, including health insurance and pensions. Currently most programs are paying field employees through the mechanisms of their partner institutions. Some ongoing problems which affect international projects are delays in subaward disbursements and fund transfers. 

Last updated: June 2, 2016