Julia:

Let me see if I understand this.  You are a 3rd tier contractor of a US Dept.
of Ed grant.  The original award was made at a restricted F&A rate by program
policy.  You are asking if your F&A rate is restricted to the first or the
second tier grantor.  Or the restrictions don't apply at all.

As a rule of thumb the fed could care less about subrecipients.  However, there
are certain "flow through" provisions.  Some are mandatory for any subaward,
some are imposed in the original award.  Reduced F&A rates may very well be a
"special term" of the original, but I have not seen this as a mandatory flow
through.

I sense that you are trying to negotiate a better F&A rate than your higher
tier is offering.  You may be stuck and will have to trust them that their
award requires a reduced F&A.  Unfortunately, they don't have to show you the
original terms.

Greg Schmidt

"Borchers, Julia" wrote:

> I would like to get some input/comment on a simple issue:
>
> Is a subcontractor on a subawardee agency award from a State Dept. of Ed
> grant issued by a "restricted indirect cost rate program" by the U.S. Dept.
> of Education restricted to the subawardee's Indirect Cost Rate OR the State
> Dept. of Ed's Indirect Cost Rate OR does this not apply to a subcontractor?
>
> Thank you.
>
> Julia G. Borchers
> Grants & Contract Specialist
> Marshall University Research Corporation
> Phone: (304) 696-2468
> Fax: (304) 696-4747
>
> "Accept your genius and say what you think." -Emerson
>
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