Re: Party Time on Federally-Funded Fixed Fee Activities? F. John Case 26 Aug 2001 10:29 EST
Deb, Circular A-122 is similar to A-21, it applies to grants, contracts and other agreements. I think it's great they would love to have a party for the volunteers, but I would be very cautious. Was this in the proposal and approved by the agency? I am sure there was excitement for this activity at the study meeting (program personnel always have great ideas), but I know if my contracting officer for any of our fixed-priced trials heard about a "party" there would be questions raised immediately. Proceed with caution and see what the contracting officer has to say about this activity. Good luck - John "Hansen, Debra" wrote: > We have a federally-funded clinical trial for which we receive payments > under a per patient (fixed fee) type agreement. The P.I. submitted a > consent form change to our IRB indicating that it was suggested at a > national meeting (directly related to this study), that the funded sites for > this clinical trial have a "THANK YOU" get together for all of the patients > enrolled in the study. Hors d'oveuvers and punch would be served and door > prizes would be distributed. Obviously, our IRB approved his request and > the study staff are now chomping at the bit to purchase the door prizes > using these fixed fee dollars because they have "approval"! (I guess we > still have some educating to do on the difference between IRB approval and > Sponsored Programs approval!) > > Anyway, in the past we have always operated under the premise that these > types of costs were unallowable under A-122, regardless of the funding > mechanism, as they are audited by our external auditors like any other > federally funded activity. Typically, our position would be that the P.I. > would need to find some other source of internal funds to cover this type of > cost vs. charging it directly to the specific federally-funded study > account. > > Can someone provide clarification (or reference to specific regulation) on > whether or not the federal regulations need to be consistently applied to > federally funded fixed fee type arrangements? Any other advise on this > specific situation would also be appreciated! > > Thanking you in advance for any responses received and extending a Happy > Friday to all! > > Deb > > Debra K. Hansen > Director of Sponsored Programs and Fiscal Affairs > Marshfield Medical Research and Education Foundation, a Division of > Marshfield Clinic > 1000 N Oak Avenue - 1R3 > Marshfield, WI 54449 > 715-387-9130 > xxxxxx@mfldclin.edu > > ====================================================================== > 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") > ====================================================================== -- F. John Case Executive Director Office of Contracts and Grants University of North Carolina at Chapel Hill CB #1350, 440 W. Franklin Street Chapel Hill, NC 27599-1350 (919) 966-2542 (919) 962-3352 (fax) xxxxxx@unc.edu ====================================================================== 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") ======================================================================