Assuming that they're using the Grants Policy Statement definition of a "recipient" which includes the grantee or any subgrantee (i.e., not including purchase orders), then I think the intent is that recipients may receive only direct costs and any applicable indirects. No profits for anybody who is deemed a recipient.

Jeffrey Ritchie
Grants Management Analyst
Aurora Health Care
3033 S. 27th Street; Ste 100
Milwaukee, WI 53215
(414) 385-2883

Elaine Brock <xxxxxx@UMICH.EDU>
Sent by: Research Administration List <xxxxxx@hrinet.org>

05/23/2007 08:51 AM

Please respond to
Research Administration Discussion List <xxxxxx@hrinet.org>

To	xxxxxx@hrinet.org
cc
Subject	[RESADM-L] Subrecipient profit

Dear Colleagues,

My subcontract administration office asked me to solicit your opinions about the following:

We have and NIH grant that contains the Prohibition on Profit clause in NIH's General Provisions 45 CFR 74
http://a257.g.akamaitech.net/7/257/2422/13nov20061500/edocket.access.gpo.gov/cfr_2006/octqtr/45cfr74.81.htm. So, we know that we can't add a fee to our budget (big surprise). Can our subcontractor add a fee to their budget since their entire budget is a direct cost to us? Is your answer different if the sub-recipient is for-profit or non-profit? How about if we treat the sub-award as a subcontract versus a purchase?
Thanks,
Elaine
Elaine L. Brock, M.H.S.A., J.D.
Senior Associate Director, Research Administration
University of Michigan
3003 S. State St., Rm, 1072
Ann Arbor, MI 48109-1274
Phone, secretary (734) 936-1289
Phone, direct (734) 763-7188
FAX (734) 763-4053
xxxxxx@umich.edu

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