Thank you for your explanation. I have worked in research administration lo these many years (over three decades, but who is counting!) and have not run into this interestingly almost unique situation! This is a nice piece of education for those of us who haven't worked with you in the past! Chuck At 08:02 PM 12/5/2002 -0800, you wrote: >Having worked in research administration in universities for over 20 years >and now as a representative of the offending nonprofit, SRI International, >I feel that I need to respond. > >Let me first clarify that nonprofits are not subject to A-21, which are >the cost principles for universities. Most nonprofits are subject to >A-122, however, SRI and others identified in Attachment C to A-122 are >subject FAR 31.2, the cost principles for commercial entities. This means >that we have multiple rates (e.g., fringe benefits, indirect costs, G&A, >support cost burden, etc.) that apply to different categories of >cost. It's really quite complicated ...and after two years I'm still not >sure how to apply all of them. > >As a nonprofit, however, we are still subject to A-110 and A-133....so, >yes, we do have an annual A-133 audit. Additionally our cognizant federal >audit agency, DCAA, has auditors located right on our campus and audit our >contracts, as well as our time keeping, accounting and procurement systems >very closely. Indeed, we are subject to much more direct government audit >oversight than most universities -- think Lockheed and not your >university's systems. > >So, why do we not reveal our rates (salary and indirect cost rates) to any >but the federal government? As it turns out, SRI is concerned about its >competitive advantage with similar type organizations with whom we >complete, primarily for contract and non-government work. If we were to >allow non-government access to our proprietary information through >subcontracting to other organizations our direct competitors could perhaps >obtain this information. So, we don't show our rates in proposals either. > >When we work with our competitors as our subcontractors, they act towards >SRI in the same manner that you find so strange. They will not provide >their rate information to us for proposals, but instead offer it to us in >sealed envelopes to pass on with our proposal to the feds or provide it >directly to the government...and we do the same when working with them >when we are the sub. Actually, this is how the commercial world works. > >Personally having worked for several different universities, and being >knowledgeable about the subrecipient monitoring requirements of A-133, I >understand that what SRI is asking sounds quite unusual....if not >inappropriate. However, we are frequently in the prime grantee role, so >we also are mindful of and try to accommodate the prime grantee's >responsibility to monitor its subrecipents...we just have to be creative >about it. And, since we do a lot of subcontracting with universities, we >have found creative ways to accommodate both parties needs....so, please, >work with us. >Thanks, >Pat > >GSchmidt wrote: >>Interesting problem here. You have an obligation as a recipient of >>federal funds to ensure that subawardees use their funds in accordance >>to A-21 and 110. You can't get out of that. Neither can they. How >>would they do an audit if they were direct recipients? Do they have to >>do an annual A-133 audit (probably do)? Couldn't you do a desk review >>of that looking at the auditor comments? That's pretty much what we do >>with each other when we do subawards with another college. >> >>You could also restructure the relationship so that it is a purchase of >>service contract and not a subaward. >> >>I am surprised, though, that a non-profit is acting like this. Usually >>if it's payroll info they want to protect, it isn't to prevent their >>competitors from knowing, its an internal privacy issue. They don't >>want their own people knowing what each other's salaries and benes are. >> >>Good luck. >> >>Greg Schmidt >> >-- >Patricia Byers >Contracts Manager >SRI International >333 Ravenswood Avenue, BS-177 >Menlo Park, CA 94025 >PH: 650-859-3571 >FAX: 650-859-3387 > > >====================================================================== >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") >====================================================================== 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://www.research.vcu.edu/ospa.htm VCU will close most faculty and staff offices from December 21, 2002 through January 5, 2003. OSPA will operate only a skeleton staff, with some limited hours, during this period. ====================================================================== 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") ======================================================================
