I believe you will find that none of the research universities wish such a
change.  In fact, in my opinion, they might actively oppose it.

The subawarded institution wants its full costs, i.e., both direct and F&A.

The subaward, technically, is like a procurement by the prime awardee
("like" because it is not competitively procured).  So the whole cost is a
direct cost to the prime.

After much battling some time ago, the research university community got
recognition that administering a sub costs administrative effort, hence the
prime's F&A on the first $25,000 of the sub was made an allowable cost (and
let me tell you, $25,000 bought five times as much research then!).

The relationship between the prime sponsor explicitly does not flow to the
subawardee.  Therefore, they cannot recognize the sub's F&A as other than a
direct cost to them, through the prime.

If you have internal accounting problems regarding treatment of your subs'
F&A, contact me at xxxxxx@vcu.edu.

Chuck

At 11:27 AM 2/24/2004, you wrote:
>Would the list please help me once again?
>
>We are trying to find out if there has been in the recent past or is a
>current effort by a group  to get federal agencies (ex. NIH) to alter their
>policy on counting subcontract F & A as a Direct project cost.
>
>If there is no effort in progress, would the means to achieve a change
>require legislation?   Is there a federal person that you know is
>knowledgeable about this issue that I might contact.
>
>Please advise and THANK YOU.
>
>Sherry Burnside, MBA
>Manager Research Programs
>Institute For Exercise and
>Environmental Medicine
>Presbyterian Hospital of Dallas
>214-345-4637
>214-345-4618 fax
>
>
>
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Herbert B. Chermside, CRA
Virginia Commonwealth University
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e-mail xxxxxx@vcu.edu

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