Hi Cari,

 

NSF polices state that foreign subrecipients that do not have a rate can use the 10% rate.

(e) Subawards²⁴ (Line G5 on the Proposal Budget)

Except for the purchase of materials and supplies, equipment or general support services allowable under the grant, no portion of the proposed activity may be subawarded, transferred, or contracted out to another organization without written prior NSF authorization. Such authorization must be provided either through inclusion of the subaward(s) on an NSF award budget or by receiving written prior approval from the cognizant NSF Grants Officer.

If known at the time of proposal submission, the intent to enter into such arrangements must be disclosed in the proposal. A separate budget and a budget justification of no more than three pages, must be provided for each subrecipient, if already identified, along with a description of the work to be performed.

All proposing organizations are required to make a case-by-case determination regarding the role of a subrecipient versus contractor for each agreement it makes. 2 CFR § 200.330 provides characteristics of each type of arrangement to assist proposing organizations in making that determination. However, inclusion of a subaward or contract in the proposal budget or submission of a request after issuance of an NSF award to add a subaward or contract will document the organizational determination required.

It is NSF’s expectation that, consistent with 2 CFR § 200.414, NSF awardees will use the domestic subrecipient’s applicable U.S. federally negotiated indirect cost rate(s). If no such rate exists, the NSF awardee may either negotiate a rate or use a de minimus indirect cost rate recovery of 10% of modified total direct costs.

It is also NSF’s expectation that NSF awardees will use the foreign subrecipient’s applicable U.S. federally negotiated indirect cost rate(s). However, foreign subrecipients that do not have a U.S. federally negotiated indirect cost rate are entitled to a de minimus indirect cost rate recovery of 10% of modified total direct costs.

 

 

http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/gpg_2.jsp

 

 

 

 

 

Hi All,

 

One of our investigators is working on an EEID grant through NSF which requires a foreign collaborator. I could not find in the solicitation or the NSF guide where foreign collaborators have a limited indirect rate like NIH. Would it be safe to assume that the foreign institution could use the 10% rate under the following clause?

 

For awardees that have never received a NICRA, 2 CFR 200.414(f) allows the use of an ICR of 10 percent calculation on MTDC. Pass-through entities may also apply this rate. If this ‘de minimis’ approach is chosen, the 10 percent rate must be applied consistently across all federal awards until the entity choses to negotiate an ICR.

 

Thanks, as always, for your help!

 

Best,

Cari

 

Cari T. Fowler, CRA

Director, Sponsored Programs

Office of Sponsored Programs, Pre-Award Division
Technology Transfer Office

University of Mississippi Medical Center

2500 North State Street

Jackson, MS 39216-4505

T: 601-815-5007 | F: 601-815-5010

xxxxxx@umc.edu

Website

 

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