I agree with Christian.  In particular, watch out for FAR 31.2 (for profit), which needs to be converted to FAR 31.3 before you accept the award, this will allow you to utilize your institutions standard travel rates, instead of being "stuck" with Joint Travel Regulations, which can be restrictive.
 
Sandra
 
Sandra M. Nordahl, CRA
Manager, Sponsored Research Administration
San Diego State University Research Foundation
5250 Campanile Drive
San Diego, CA  92182-1934
619.594.4172 (voice)
619.582.9164 (fax)
e-mail:  xxxxxx@foundation.sdsu.edu


From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Reneau Lorenzi, Kathleen
Sent: Thursday, March 15, 2007 8:29 AM
To: xxxxxx@hrinet.org
Subject: Re: [RESADM-L] Federal dollars passed through private contractor

We are seeing the same thing and our experience is mixed.  Christian’s comments are well taken.  I will add that we are also being required (or at least they are trying to require) us to work on a T&M basis.  The typical request if for us to fit our PI and researcher salaries into their negotiated labor rate list (this does not work well…).  So far we have pushed back pretty successfully.  IDIQs are OK but terms have to be university friendly and each task order has to be on our normal financial terms.

 

One other thing to look for – all these big Schedule or IDIQ contracts tend to pass down very broad SOW requirements and have very broad Organizational Conflict of Interest clauses – typically the SOW and OCI language is directly from their prime without tailoring for the tasks they really want the university to do.  Watch closely for this.  It is a good idea to ask your PI to narrow down their expected subcontract scope of work to very specific areas within their expertise in order to avoid any inadvertent conflicts of interest problems later on.

 

Kathy

 

Kathleen Reneau Lorenzi, CPCM

Office of Sponsored Projects

The University of Texas at Austin

 

Phone:     512-471-2335

FAX         512-471-6564

Email:      xxxxxx@austin.utexas.edu


From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Christian Hess
Sent: Thursday, March 15, 2007 7:21 AM
To: xxxxxx@hrinet.org
Subject: Re: [RESADM-L] Federal dollars passed through private contractor

 

We have seen situations where gov program managers prefer to use contractors that have either a GSA schedule contract or an IDIQ with the particular agency so they don't have to bid the requirement.  If there is no solicitation out for this research, chances are this is what is happening.

 

Particular pitfalls: Make sure the clauses in your subcontract are appropriate.  Many times contractors will flow down the same clauses as their prime award, which apply to for profit corporations.  Watch out for added indemnification, rights in data, etc.  Same things you normally do with private agreements.

 

 

Christian Hess
Project Development Officer
Indiana University of Pennsylvania Research Institute
(724) 357-1344 [office]
(724) 357-7697 [fax]
(724) 464-4954 [wireless]
xxxxxx@iup.edu

 

 

 

 

----- Original Message -----

From: Office OF Research

To: xxxxxx@hrinet.org

Sent: Wednesday, March 14, 2007 5:48 PM

Subject: [RESADM-L] Federal dollars passed through private contractor

 

One of our faculty members has the opportunity to perform research funded by the Army Corp of Engineers.  The Corps prefers to “pass the funds through” a private consultant who would then contract with our university to conduct nearly all of the scope of work for the project.  The Corps already has a relationship with this consultant, and our faculty member has worked with him quite a lot in the past.

 

Any particular pitfalls we should be aware of as we consider this arrangement?  Should we comfortably accept Federal dollars through such an arrangement?  You can respond to my email below if you prefer not to include the whole discussion group…

 

 

 

Brian Mathers

Coordinator of Sponsored Programs

University of South Dakota

414 East Clark Street

Vermillion, SD 57069-2390

(605) 677-5370

xxxxxx@usd.edu

 

 

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