I agree, good question. Interested in how other offices interpret this.

 

Lacey, I saw the multi-project policy you shared from UCSF, and I am confused even more.  I wonder what their argument is for the delineation of sub-costs on Multis.  Multi-project proposals include a specific form to detail the aggregate costs of each subaward organization that leads a component to facilitate the calculation of the F&A on its first 25K.

 

Also, is there a different interpretation of how to apply this depending on the way the supplemental funds are being awarded?  Usually, they are awarded under “3” but in some cases, a new NOA is released increasing the funding as a “5” – revised.  NOAs state that the additional funding is restricted for the stated supplemental purpose.  Would this restrictive language give justification for the need to clearly delineate accounting as Connie referenced?  But also, possibly be an argument for the inclusion of these additional funds in the total for the purpose of F&A allocations? 

 

The parent funding announcement also references that any award made in response to the FOA is subject to the T&C.  The big question is how the institution defines the MTDC for the sake of calculating the F&A base, specifically the language stating “each” subaward.  Further confusing things, the CFR has two definitions listed to describe both a “subaward” which is the legal mechanism used to award pass-through funds, and “subrecipient” which is defined as the entity that receives a subaward.  If I understand correctly, wouldn’t this mean that a subrecipient entity could receive multiple subawards under the same project?  If I follow Connie’s explanation, this would mean that each legal agreement is separate “a subaward”, for the purpose of determining F&A base as opposed to if the language stated “each subrecipient” which would be more geared towards the entity receiving funds under the umbrella of the parent project.

 

Thoughts?

 

Meredith Al-Rekabi
Grants Manager

Office of Sponsored Programs and Research 
CUNY Graduate School of Public Health & Health Policy
55 W. 125th Street | New York, NY 10027
xxxxxx@sph.cuny.edu  |  sph.cuny.edu  |  (727) 486-1017 

 

 

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> on behalf of Motoki, Connie <xxxxxx@wustl.edu>
Date: Wednesday, September 27, 2023 at 12:28 PM
To: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org>
Subject: RE: [RESADM-L] supplement subaward and indirects

* This email originates from a sender outside of CUNY. Verify the sender before replying or clicking on links and attachments. *

Great topic:

Our sponsored program office managers were just discussing this and searching NIH last week for documentation on how to treat supplemental funding.

Washington University has adapted the practice of setting up new subawards for supplemental projects, and we take the F&A on each sub under a supplement award.  In my experience, the NOA often requires a separate accounting of the supplemental funds.

 

See what I found:

Funding Opportunity Title

Administrative Supplements to Existing NIH Grants and Cooperative Agreements (Parent Admin Supp Clinical Trial Optional)

Activity Code

Administrative Supplement

Additional funds may be awarded as supplements to parent awards for all activity codes.

Announcement Type

Reissue of PA-18-591

3. Reporting

Reporting requirements will be specified in the terms and conditions of award as applicable to the supplemental activities. In most non-competing continuation applications, the progress report and budget for the supplement must be included with, but clearly delineated from, the progress report and budget for the parent award. 

We’ve interpreted this to track separately the supplemental award expenses, including any subawards.   

 

Thank you,

Connie

 

_____________________________________

Connie L. Motoki , CRA | Grants Manager

Washington University in St. Louis  |

One Brookings Drive  |  Campus Box 1054 |  St. Louis, MO 63130   
Phone:  314.747-5272 |   xxxxxx@wustl.edu

Office of Sponsored Research Services :: Office of the Vice Chancellor for Research

 

 

 

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> On Behalf Of Lacey Rhea
Sent: Monday, September 18, 2023 8:59 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] supplement subaward and indirects

 

Great question that I can’t believe isn’t covered by an NIH FAQ, it comes up so often.  My understanding is that the $25k doesn't reset for each activity.  Though it is a separate scope of work, it is still one subaward relationship under one NIH award.  The compartmentalizing of it into separate buckets is an internal choice; from the NIH's perspective it is all one pot of money.

 

I can't seem to find anything in UG or NIH that addresses this exactly, but past experience informs my opinion, and here are some institutional interpretations that agree:

 

 

And for fun, here is one that DOES NOT agree with me (though this seems specific to multiple-project awards such as the NIH P series):

 

 

And finally, here are previous listserv conversations on this topic, which also are not definitive (taken from the RESADM-L Archives):

 

 

Best of luck.

 

Lacey Rhea

Research Administration Manager and Mentor

(c) 352-235-0756; xxxxxx@gmail.com

LinkedIn:  https://www.linkedin.com/in/lacey-rhea

DISCLAIMER:  The views expressed here are my own and not those of my employer.  

 

 

 

On Sun, Sep 17, 2023, 4:36 PM Elliott-Farino, Carolyn E <xxxxxx@mainehealth.org> wrote:

This is probably an easy question for someone. We have a large NIH grant with a partner university; we are the lead and issue a subaward to our partner, amending it annually. We have received several supplements to the large parent grant and issue subawards from the supplement (not amendments to the main parent grant subaward) to this same partner, so they now have more than one subaward under the same parent grant.  I was just asked by one of our accountants whether we could charge indirects on these separate subawards (which are for different activities).

 

My initial reaction was yes, because these are separate subawards and our base says “that portion of each subaward in excess of $25,000”:

 

So separate subawards each max out at $25,000 for calculating indirects.  But since the subs are all off the same parent grant, have I come to this conclusion erroneously? Now I am doubting myself.

 

Thus, the question is: If you have multiple subawards to the same subrecipient off the same parent grant, can you charge indirects off each subaward?

 

I think I have overthought this and appreciate any guidance you can provide.

 

Carolyn

Carolyn Elliott-Farino, MA, CRA  (she/her)

Director, Research Grants

Authorized Organization Representative (AOR)

MaineHealth Institute for Research

81 Research Drive, Scarborough, ME 04074

207-396-8188

xxxxxx@mainehealth.org

 

PATIENT CENTERED | RESPECT |  INTEGRITY | EXCELLENCE | OWNERSHIP | INNOVATION

 

 

 

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