I have just worked at non-Ph.D. granting institutions with low volume
sponsored agreements for many years and I may have lost my RA
skills. Yesterday I talked with a veteran auditor/consultant regarding
developing an F&A (indirect cost rate) proposal for a community
college. This consultant has extensive experience in developing F&A
proposals for colleges and universities in California and across the
country. Two issues came up that I did not expect. First, the consultant
indicated that a long form F&A proposal was not applicable except for
research grants, and secondly, that under OMB A-21's definition,
'developing new curriculum' was not 'research and development'.
My current thinking is that the long form applied to all types of sponsored
agreements, though the negotiated agreement may have separate rates for
research, training, public service, on-campus, off-campus, etc. I also
thought that research was the methodology used to advance knowledge or
develop an outcome or product, but I got the impression from the consultant
that work to develop new methods in educational pedagogy, even if it
involves human subjects, was not research. Specifically, the consultant
considered NSF ATE grants, and CCLD grants non-research grants with no
regard to project activities.
I would appreciate feedback, especially from those individuals at
institutions that conduct non-medical research. The impression I got from
the consultant was that qualitative and quantitative research, action
research, and other research in the social sciences and in education may
not be research under OMB A-21 definitions and that a long form is
inappropriate unless the sponsored projects are basic research under this
definition.
Thank you for your input.
Mary Susan Barbosa, CRA
Grants Officer
Glendale Community College
1500 North Verdugo Road
Glendale, CA. 91208-2894
telephone: (818) 240-1000, Extension 5823
fax: (818) 549-9436
email: xxxxxx@glendale.edu
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