Mary

The language and limitations on IC recovery against
subcontracts is not in A-21, it is in your (F&A) Rate Agreement
with your cognizant Federal audit agency.

The Feds consider the entire project period, not just each
individual budget period, when making the determination. Once
you do $25,000 in business with a subcontractor, you’re done
charging IC (oops F&A) on their costs. It doesn’t matter if it is
one year or more.

Also, one of the key items is the nature of the relationship. If it is
an on-going relationship, no further IC will accrue – even across
continuation grants (as opposed to multiple budget periods
within one grant).

The Feds do allow you to set the money limit back to zero if, as
the result of a new competitive bid process, an existing
subcontractor is rehired. That would be considered a new
relationship and a new $25,000 limit would exist.

If, however, you call an existing subcontractor and merely tell
them to do more work, not IC can be charged on any portion
over $25,000

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
 Larry Waxler, Director                 |
 Office of Sponsored Programs           | TELEPHONE: 207-780-4411
 University of Southern Maine           | TELEFAX:   207-780-4417
 P.O. Box 9300                          | E-MAIL:    xxxxxx@usm.maine.edu
 96 Falmouth Street                     | WEB:       www.usm.maine.edu/~osp
 Portland, Maine  04104-9300            |
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================