Long form vs short form is a function of the sponsored program activity of
the institution:
A-21 H.1.a. "Where the total direct cost of work covered by Circular A-21
at an institution does not
 exceed $10 million in a fiscal year, the use of the simplified procedure...."

"Developing new curriculum" might be research and might be
instruction.  More likely the latter, but if you were actually doing a
controlled experiment comparing two/several curricula and measuring the
outcome by some reliable test of mastery of material presented, it surely
would be research.  I just don't think you will find anyone who will fund
an experiment like that with a large enough N to provide viably
generalizable data.

I don't understand the basis of some of this particular consultant's
statements.

Chuck

At 08:54 PM 3/20/2002 -0800, you wrote:
>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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Herbert B. Chermside, CRA
Director, Sponsored Programs Administration
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Express Delivery Only:
 Sanger Hall, Rm. 1-032A
 11th & Marshall Streets
 Richmond, VA  23219
Voice:  804-828-6772
Fax     804-828-2521
OFFICE e-mail   xxxxxx@VCU.EDU
Personal e-mail xxxxxx@vcu.edu
http://views.vcu.edu/ospa/

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