Hi Lori,

I was I this exact situation with on the receiving end when faculty member transferred to my department.

Yes NSF will allow this.
My understanding is that the F&A on the new sub cannot be waived.

Thank you.

Vicky

Vicky Ortiz Batson, MA

Grants & Contracts Manager

Lead Research Administrator

Department of Pharmacology and Cancer Biology

Duke University School of Medicine

308 Research Drive, Durham, North Carolina 27710

Phone: 919-684-8007

xxxxxx@duke.edu

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org>
Sent: Friday, April 14, 2023 6:51 PM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] Charging Indirect on a new Subaward

Hello Hive Mind!

I hope you can help me navigate this situation.

We are on a subaward under an NSF grant and one of our Co-PIs has moved to another institution. NSF has already approved for the prime grantee to create a new subaward under the original grant, but since they will be charging overhead on the new subaward, we are concerned that there will be fewer dollars available for the research. Given this situation I have a few questions.

1. Does NSF allow for a subaward on a subaward?

2. Can indirect charges on a subaward be waived? Is this allowed under federal regulations, or is it dependent on institutional policy?

I did find this under the NSF PAPPG. If IDC was not charged on the first $25K of a subaward would it be considered a cost share violation? Or am I reaching?

Use of an indirect cost rate lower than the organization's current negotiated indirect cost rate is considered a violation of NSF’s cost sharing policy. See section (xii) below. The amount for indirect costs should be calculated by applying the current negotiated indirect cost rate(s) to the approved base(s), and such amounts should be specified in the budget justification.

Lori

—

Lori Kam
Sponsored Research Pre-Award Specialist
Santa Fe Institute
http://www.santafe.edu
505-946-2727
xxxxxx@santafe.edu

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