Thanks Michelle and the others who responded, some off-line. This is typical DoEd. Two responses indicated they used 8% (both were from the same university system, it looks like, but answered independently of the other), one used their full rate, and then this response.

 

We are using the training rate, but I’m trying to document which rate is really allowable to determine if we need to do an F&A waiver. We will need to do a waiver, but clearly we have documentation to back it up. This seems to be a real grey area – it was this part of the solicitation, combined with my reading of the CFR, that got me wondering:

developing, implementing, documenting, evaluating, and disseminating innovative, cohesive models of professional development.

That seems to be more than just training, in my book, and Ed thinks it is, too. What it comes down to is having a solid, cost-effective proposal. What a surprise!

 

Cheers and thanks again for the input. You’ve helped tremendously, and perhaps others have benefitted from this information, as well.

 

CEF

 

 

Carolyn – I actually asked the program officer (Alex Stein) about that issue last year when I was working on a TAH proposal with our faculty. 

 

My question to Dr. Stein was:

 

I am helping a couple of my faculty who are working with an LEA which will be submitting.  We have a question regarding indirect costs …I note that they are allowed and that the LEA applicant should use its own indirect costs rate and that our indirect costs would be included under contractual (in their submitted budget).  Is there a limit to the amount of indirect we can request as the IHE’s part?  Our authorized rate is 46% but typically when we submit US Dept of Ed proposals we are capped at 8% or so.  Please confirm the Ed’s wishes on what the contract partners should/can collect for indirect costs.

 

Dr. Stein’s response was:

 

Dear Michelle Hoversten,

 

No there is no limit to what you can submit contractually. Of course, in submitting the application the more information you provide about your contractual rate, the more information the panel reviewers will have in order to rate your grant relative to cost items in its management plan.

 

Alex Stein

 

 

Cheers,

Michelle

 

 

The Teaching American History Grant (TAH) Program supports projects that aim to raise student achievement by improving teachers’ knowledge, understanding, and appreciation of traditional American history. Grant awards assist local educational agencies (LEAs), in partnership with entities that have extensive content expertise, in developing, implementing, documenting, evaluating, and disseminating innovative, cohesive models of professional development. By helping teachers to develop a deeper understanding and appreciation of traditional American history as a separate subject within the core curriculum, these programs are intended to improve instruction and raise student achievement.

 

Does anyone know if this program is what DoEd terms an educational training grant, i.e. an 8% indirects limit? And is there a listing somewhere of these educational training grants? The solicitation says nothing about an 8% limit (the lead must be an LEA and they are to use their approved rate; there is no guidance on F&A for the required subawardees/partners), and I have done some fun reading today in 34 CFR 75.562 about educational training grants:

 

§ 75.562 Indirect cost rates for educational training projects.

(a) Educational training grants provide funding for training or other educational services. Examples of the work supported by training grants are summer institutes, training programs for selected participants, the introduction of new or expanded courses, and similar instructional undertakings that are separately budgeted and accounted for by the sponsoring institution.

These grants do not usually support activities involving research, development, and dissemination of new educational materials and methods. Training grants largely implement previously developed materials and methods and require no significant adaptation of techniques or instructional services to fit different circumstances. (b) The Secretary uses the definition in paragraph (a) to determine which grants are educational training grants. (c) Indirect cost reimbursement on a

training grant is limited to the recipient’s actual indirect costs, as determined by its negotiated indirect cost rate agreement, or eight percent of a modified total direct cost base, whichever amount is less. For the purposes of this section, a modified total direct cost base is defined as total direct costs less stipends, tuition and related fees, and capital expenditures of $5,000 or more.

 

Thank you.

 

Carolyn Elliott-Farino

Director, Contracts and Grants Administration

Kennesaw State University

770.423.6381

xxxxxx@kennesaw.edu

 

 

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