It sounds as if an indirect cost rate other than your negotiated rate was used.  In this case the agency rate can still be charged even though you no longer have salaries.  It is only when you use your negotiated rate that your scenario would be true.  You still can charge indirects on this particular program as long as you don't go over the bottom line.  The best example I can give would be a U.S. Department of Education program such as Student Support Services.  The Department of Education only allows 8% MTDC (minus any stipends and tuition and fees).  You cannot use your indirect rate on this.  Even if you moved all the salaries out, you still could recoup at the 8% rate.

Zoya Hamilton wrote:

Hello,

 

Our University indirect cost rate is based on salaries and wages. I am looking for a reference that would substantiate my position that if there are no salaries charged to the grant, no indirect costs may be charged either. Sounds like that is obvious, but consider this example.

 

The agency limited IDC for a specific funding opportunity to a percentage of direct costs. The PI budgeted some salaries in the proposal, and the agency-limited rate turned out to be lesser than the university rate in the proposed budget. Therefore, the agency rate was used in the proposal. In the middle of the grant the PI rebudgeted salaries internally to non-salary costs. No salaries were charged to the grant at all. I contend that in this case we cannot charge any IDC. Do you agree?

 

I was able to find the language indirectly supporting my position in A-21, but not clear enough to persuade others. Any thoughts would be greatly appreciated.

 

Zoya Hamilton

Associate Director of Research and Sponsored Programs

University of Arkansas at Pine Bluff

Mail Slot 4978, 1200 North University Drive

Pine Bluff, AR 71601

tel. 870-575-8076; fax 870-575-4672

www.uapb-orsp.net

 

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