WHY did you elect to waive F?  Who is sponsor?

Broadly, I would say that it is appropriate to direct charge some of the F
costs.
IF the sponsor is federal, be sure to have a clear statement of why the
waiver and why some F items  charged directly.  Good idea even if not
federal sponsor.
IMPERATIVE that the accounting for this be done in a manner that the costs
that were recovered by direct payment DO NOT get into the F pools (or are
offset by the income) when computing F&A proposals.
AND get approval for this from those involved in the F&A proposals and cost
accounting.  There might be an effect on the DS-2 -- a change in accounting
practices -- that is unacceptable to overall institutional interests.

And this should be a single case with good reason, rather than a general or
frequent practice, or there WILL ba a major DS-2 impact.

Chuck

At 08:27 AM 1/29/2004, you wrote:
>Since the hot topic of the last few days seems to be F&A topics, I have
>one more.  In a case where we have negotiated to waive the facilities
>portion of our F&A rate on a specific program, can we choose to direct
>charge some of the items that might have been included in that portion of
>the F&A rate?
>
>Mike
>Michael P. Gilles
>Senior Contracts Analyst
>Research & Sponsored Programs
>Michigan Technological University
>1400 Townsend Drive
>Houghton, MI 49931
>Ph: 906 487-2225  Fx: 906 487-2245
>
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Virginia Commonwealth University
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