Suggest that you NOT try to collect certain F costs in this case.  Clearly,
the federal source has problems with it.

But you might reconsider the master agreement in light of this, and make
the limit of F&A to admin only NOT applicable to federal flow-through.  I
presume that you made that agreement pursuant to some consideration of
state funds supporting some facilities costs, and that argument would not
apply to federal flow through!

Chuck

At 10:27 AM 1/29/2004, you wrote:
>The sponsor is MDOT, Michigan Department of Transportation and the money
>is federal pass-through from FHWA.  We had negotiated a Master Agreement
>with MDOT to charge 26% which is the cap on our Admin portion of our
>F&A.  MDOT had no problem with some of the direct charges but he FHWA
>auditors were.
>
>
>
>
>At 10:01 AM 1/29/2004, you wrote:
>>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
>>>
>>>======================================================================
>>>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
>>Virginia Commonwealth University
>>PO BOX 980568
>>Richmond, VA  23298-0568
>>Voice:  804-827-6036
>>Fax     804-828-2051
>>e-mail xxxxxx@vcu.edu
>>
>>
>>======================================================================
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>>subscription information and a web-searchable archive, are available
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>>======================================================================
>
>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
>
>======================================================================
>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
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Voice:  804-827-6036
Fax     804-828-2051
e-mail xxxxxx@vcu.edu

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 Instructions on how to use the RESADM-L Mailing List, including
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