Hi all,

For this discussion I'm referencing the following announcement:
http://www.doleta.gov/grants/pdf/SGA-DFA-PY-10-06.pdf

Starting on page 19 of this announcement, it talks about Indirect Costs and Administrative Costs.

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1. Indirect Costs
As specified in OMB Circular Cost Principles, indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. An indirect cost rate (ICR) is required when an organization operates under more than one grant or other activity, whether Federally-assisted or not. Organizations must use the ICR supplied by the Federal Cognizant Agency. If an organization requires a new ICR or has a pending ICR, the Grant Officer will award a temporary billing rate for 90 days until a provisional rate can be issued. This rate is based on the fact that an organization has not established an ICR agreement. Within this 90 day period, the organization must submit an acceptable indirect cost proposal to their Federal Cognizant Agency to obtain a provisional ICR.
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Fine, that makes perfect sense and we have an agreement with ONR for our negotiated F&A rates.

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2. Administrative Costs
Under this SGA, an entity that receives a grant to carry out a project or program may not use more than 10 percent of the amount of the grant to pay administrative costs associated with the program or project. Administrative costs could be direct or indirect costs, and are defined at 20 CFR 667.220. Administrative costs do not need to be identified separately from program costs on the SF-424A Budget Information Form. However, they must be tracked through the grantee’s accounting system. To claim any administrative costs that are also indirect costs, the applicant must obtain an Indirect Cost Rate Agreement from its Federal Cognizant agency, as specified above.
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This section is what makes it confusing, but it seems to be saying we shouldn't charge more than 10% of total project costs to Dept. of Labor as our F&A rate, since we don't direct charge administrative costs, but would be charging indirect costs. Does this make sense? What F&A rate should be used?

Thanks,
Andrew
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Andrew Parkerson-Gray, CRA
Director, UAF Office of Sponsored Programs
909 Koyukuk Drive / P.O. Box 757270
West Ridge Research Building, Suite 212F
Fairbanks, AK 99775-7270

Phone:  (907) 474-1851
Fax:    (907) 474-5444
E-mail: xxxxxx@alaska.edu
Web:    http://www.uaf.edu/osp/
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