Good morning,

Our institution is receiving some appropriation funds from the USDA.  My understanding of this (I am coming in on the back side of this) is that the funds were originally supposed to go through another institution in MS, but, for whatever reason—perhaps due to the death of the original submitter of a white paper several years ago—the funds are coming here.  That being said, this is the first time we have worked with the USDA, so this is new territory.

For those of you familiar with the USDA, the mechanism by which this will be awarded is a NACA and the budget instructions state that state cooperative institutions cannot be reimbursed for IDC [n]or tuition.  Non-profit entities are limited to a 10% reimbursement of total DC.

An educated guess led me to believe that we are not a state cooperative institution and the MU Research Corporation, which acts on behalf of the university, is a separate non-profit 501c3 corporation, which would allow us to charge 10% IDC, so I emailed this question to the USDA folks.

Question for my colleagues:  am I correct with the assumption that we can charge 10% indirects based on the USDA answer below:

“Under 7 USC 3319, USDA is prohibited from reimbursing State Cooperative Institutions for indirect costs or tuition remission in connection with non-assistance cooperative agreements awarded under the authority of 7 USC 3318(b). See Notes to the REE-451 Budget attached.  Indirect costs will be reimbursed only upon receipt of a current approved Negotiated Indirect Cost Rate Agreement (NICRA) for all non-State Cooperative Institutions.  If Marshall University has a Federal Negotiated Cost Rate Agreement, then this cost rate must be accepted by all Federal awarding agencies. 

The Federal government cannot ask the Non-Federal Entity “NFE” to be reimbursed for less than their negotiated indirect cost rate.  The Federal government cannot negotiate with the NFE to be reimbursed for a lesser indirect cost rate than the NFEs published rate.”

Lisa S. Daniels, CRA, CPRA
Grant & Contract Officer

Joan C. Edwards School of Medicine at Marshall University
Marshall University Research Corporation
1 John Marshall Drive, BBSC 435M
Huntington  WV  25755-0002

xxxxxx@marshall.edu
phone:  (304)  696-3368