I think exclusion of F & A only applies to first-tier consortium. See below taken from NHLBI/NIH link http://www.nhlbi.nih.gov/funding/policies/500kweb.htm

Applications with Direct Costs of
$500,000 or more in any one year

National Heart, Lung, and Blood Institute
National Institutes of Health

Revised: June 26, 2013

A. Purpose

This document describes the National Heart, Lung, and Blood Institute (NHLBI) implementation of the NIH policy requiring all applications that request $500,000 or more in direct costs in any year to be accompanied by a letter from the Institute stating that it will accept the application.

B. Scope

This policy applies to any investigator-initiated new, renewal (competing continuation), resubmission (amended), or revision (competing supplement) application requesting $500,000 or more in direct costs in any year. First-tier consortium or contractual facilities and administrative (F&A) costs do not count against the direct cost limit.

Sonavie Ong

Grants Manager

Office of Sponsored Research

Hawai'i Pacific University

1164 Bishop Street, Suite 500

Honolulu, HI 96813

Telephone: (808) 544-9338

E-Mail: xxxxxx@hpu.edu

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Wood, Roger
Sent: Friday, August 30, 2013 10:04 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Direct Cost Limit - Third Tier F&A Question

Joanne,

Consistent with how standard sub awards work, the total costs of the third-tier sub award formally include both directs and indirects of the sub – as direct costs on the second-tier sub and, by extension on the prime. However, for purposes of assessing compliance with NIH direct cost limits on awards (e.g., the $500,000 annual costs rule), the third-tier sub award costs would be excluded just as would the second-tier sub award indirect costs.

Roger

Roger Wood, SR PRODUCT MANAGER
xxxxxx@infoedglobal.com | +1.518.713.4200 ext 150

From: Joanne Cobble <xxxxxx@FOUNDATION.SDSU.EDU>
Reply-To: Research Administration Discussion List <xxxxxx@lists.healthresearch.org>
Date: Friday, August 30, 2013 3:36 PM
To: "xxxxxx@lists.healthresearch.org" <xxxxxx@lists.healthresearch.org>
Subject: [RESADM-L] Direct Cost Limit - Third Tier F&A Question

We are trying to confirm if we would exclude the third tier subcontract F&A for the purposes of calculating the direct cost prior approval letter?

The NIH guidance isn’t very clear…

Thank you. Joanne

· Direct costs:

o In the rare case of third tier subawards, section F.5 “subawards/consortium/contractual” costs should include the total cost of the subaward, and the entire third tier award is considered part of the direct costs of the consortium for the purposes of calculating the primary applicant’s direct costs.

o Cost Principles. Regardless of what cost principles apply to the parent grantee, the consortium is held to the standards of their respective set of cost principles.

· F&A:

o Consortium F&A costs are NOT included as part of the direct cost base when determining whether the application can use the modular format (direct costs < $250,000 per year), or determining whether prior approval is needed to submit an application (direct costs $500,000 or more for any year).

Joanne Cobble
Sponsored Programs Coordinator
Sponsored Research Development
San Diego State University Research Foundation
5250 Campanile Drive
San Diego, CA 92182-1931
619-594-5505
619-594-4950 (fax)
xxxxxx@foundation.sdsu.edu
http://www.foundation.sdsu.edu

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