I had another one as well. ARPA-e decided that the $2,800 vacuum pump was equipment because it would be connected to the $8,000 custom fabricated print head. Nope – that’s a standalone item and is not permanently part of the capital equipment so they got the toilet analogy because they are not taking away our F&A on that.

“It is like a toilet and the water line for it. The toilet is an integrated piece of equipment and only functions as a unit, but the water line is separate, replaceable supply item.”

Susan

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> On Behalf Of Julia R. Pierce
Sent: Thursday, November 30, 2023 9:00 AM
To: xxxxxx@lists.healthresearch.org
Subject: RE: [RESADM-L] DOE GRANT: Commercial Vendor vs subrecipient

You don't often get email from xxxxxx@calpoly.edu. Learn why this is important

[This email originated from outside of OSU. Use caution with links and attachments.]

Susan,

What a great response and analogy! Thanks for sharing.

Julia Pierce

(805) 756-1123 Main

(805) 756-5347 Direct

xxxxxx@calpoly.edu

Contracts & Grants Analyst

Sponsored Programs Office

Cal Poly Corporation

Bldg. 38, Room 102

1 Grand Avenue

San Luis Obispo, CA 93407

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> On Behalf Of Cao, Susan
Sent: Thursday, November 30, 2023 8:44 AM
To: xxxxxx@lists.healthresearch.org
Subject: RE: [RESADM-L] DOE GRANT: Commercial Vendor vs subrecipient

I am really starting to wonder about some of the DOE specialists requests at award negotiations lately. Are they not getting very good training or are they getting pressured to get more and more information?

Someone posted on here that they got a request for the CV of the Business Contact (AOR) at their institution? Really?

I had one a while back where they wanted us to breakdown a standard commercial fee as well. We had a contractor who was going to get on a boat, dig a hole in the ocean floor and take measurements and analyze the data. The cost was a flat fee per hole of $75 like they charge all their customers.

EERE came back saying that since the contractor’s staff was going to be doing this work, we needed to break down that fee per hole into personnel and benefit costs etc.? I came back with the following which got them off my back: “When you buy a loaf of bread in the store, you pay the price listed on the shelf tag. You cannot calculate out the cost of the baker’s time, the gas for the delivery truck, and the hourly wage of the person stocking the shelves.”

Susan

From: xxxxxx@lists.healthresearch.org <xxxxxx@lists.healthresearch.org> On Behalf Of Kirsten Torguson
Sent: Wednesday, November 29, 2023 4:39 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] DOE GRANT: Commercial Vendor vs subrecipient

[This email originated from outside of OSU. Use caution with links and attachments.]

Hi Shannon, I have a client who is in the same boat. My small business client wrote in a large business as a "service provider" (not a sub OR vendor), and now DoE is pushing for us to re-do our budget justification and categorize them as a sub. They are in no way set up to be a federal subawardee (no policies, T&E systems, separation of ledgers for projects, documentation of fringe, etc.), and my client, as the prime, has pushed back saying that this is an audit risk for them. The challenge is that in the original solicitation it stated that vendors can't provide cost-sharing, and the entirety of this sub / service provider's contribution is match.

I guess my question is whether you are really set up to be a federal subawardee, and whether you can comply with all of the regulations that entails? It is also my understanding from the guidance that the justification only needs to be completed for budgets over $250,000, but DoE does things their own way, so they may in fact require you to complete it.

My client had to restructure their entire budget to provide the mandatory cost-sharing themselves, which is a huge hit. There's just no way around this for us. I'd love to hear how you resolve this. I'm happy to chat if you'd like. Kirsten

On Wed, Nov 29, 2023 at 1:58 PM shannon knudsen <xxxxxx@gmail.com> wrote:

Hi All,

Hoping for guidance from this community. I was a research admin for over 10 years and I am stumped.

My consulting firm is part of a consortium that has been awarded a cost reimbursable Department of Energy (DOE) BIL/IRA funded grant. We're a for profit LLC Partnership, so we don't have regular salaries. Instead, like consultants, we charge rates by the hour or by the job, and we take home as profit whatever we don't spend on expenses for the job. We offer varying rates by client so establishing an institutional base salary would be challenging at best.

For the DOE project that was selected for award negotiations, we are being asked to complete a subrecipient budget justification worksheet that includes salary, fringe, supplies, IDC, etc, and there's no budget line item for profit. As I mentioned, we don't have regular salaries, so I'm concerned with inputting salaries and fringe that align with our rates, when our internal financials will not support the salary or fringe expense line items that we'd be asked to submit when it comes time for reimbursement.

Final piece of the puzzle, there's an instruction in the budget justification worksheet itself on the contractual tab that distinguishes between commercial vendors (us) and subrecipients, and it says that commercial vendors with budgets over $250k should provide a quote, which makes sense. However, because of the Q&A provided by the sponsor, the impression is given that even commercial vendors must complete the subrecipient budget justification worksheet if their budget is over $250K.

Is there a way to legitimately fit a for profit rate-based structure for an SoW into a not-for-profit subrecipient budget format, or are we setting ourselves up for failure by accepting this request, and should we continue to push for providing a vendor quote with the requisite hourly rates, hourly estimates by task, etc?

I know there are a lot of details to this so feel free to contact me directly. Thanks for any advice you can offer.

Best,

Shannon Knudsen

571.723.0601

xxxxxx@gmail.com

Pronouns: he, him, his

- = - = - = - = - = - = -

This email was sent to xxxxxx@TORGUSONASSOCIATES.COM via the Research Administrator's mailing list.

To unsubscribe from RESADM-L, go to https://lists.healthresearch.org and go into the Account Settings area.

List archives are available at: https://lists.healthresearch.org/resadm-l

To change your settings (such as Digest Mode or to temporarily suspend list emails): https://lists.healthresearch.org

Kirsten Torguson, MS, CRA

Founder & Senior Consultant

Torguson & Associates, LLC

Research Administration Consulting

torgusonassociates.com

541.499.0400

You do the science ... we do compliance!

- = - = - = - = - = - = -

This email was sent to xxxxxx@oregonstate.edu via the Research Administrator's mailing list.

To unsubscribe from RESADM-L, go to https://lists.healthresearch.org and go into the Account Settings area.

List archives are available at: https://lists.healthresearch.org/resadm-l

To change your settings (such as Digest Mode or to temporarily suspend list emails): https://lists.healthresearch.org

- = - = - = - = - = - = -

This email was sent to xxxxxx@calpoly.edu via the Research Administrator's mailing list.

To unsubscribe from RESADM-L, go to https://lists.healthresearch.org and go into the Account Settings area.

List archives are available at: https://lists.healthresearch.org/resadm-l

To change your settings (such as Digest Mode or to temporarily suspend list emails): https://lists.healthresearch.org