Hi, Lori—
Let me channel Jean Feldman for a second on your second question and point out that waiving indirects on a subaward would constitute voluntary committed cost-sharing which is expressly prohibited by NSF policy.
At a previous institution, we had a long-standing S-STEM consortium that had been voluntarily waiving part of each institution’s indirect costs since the original proposal was submitted, decades before I came on the scene. Our policy was that on a continuation, we used the same indirect cost rate that had been used on the original proposal (following the UG’s provision about IDC rates lasting for the life of the project). But When NSF formally prohibited voluntary committed cost-sharing, we were told we had to start charging full indirects or we’d be in violation of the policy. It’s not exactly the same situation you’re in, but I think it’s relevantly similar.
And yes, you can have a sub off of a sub.
Michael Spires, M.A., M.S., CRA
(He/him/his)
Research Development Officer
The Research Office
Oakland University
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From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org>
Sent: Friday, April 14, 2023 18:51
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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