From your description it appears that the university will be making a
procurement contract for services, rather than a subaward, because the
subcontractor is not making a substantive contribution to the
research.  Presumably any competent subcontractor could provide these
services -- even if it has to be a sole source procurement because that is
the only qualified subcontractor.  Therefore the university should collect
full F&A on that procurement.

"Subcontract" is a slippery word.  It really means only a contract
subsidiary to a prime agreement.  A-110 gives some good language about the
difference between a "subgrant" or "subaward" and a mere procurement.  Even
if your prime federal agreement is a contract, the reasoning is the
same.  I personally prefer "subaward" for a collaborative subagreement,
just to keep the difference clear in your mind, but that's a kind of
specialized use not well recognized except by other research
administrators.  There can be added confusion if a subaward needs a P.O.
from your procurement people to go along with a subaward for administrative
reasons.  I believe the subaward should be written by the research
administrators because of the significant flow-downs required, whereas a
procurement, even under federal funds, needs very little flowdown of
federal requirements; the institution probably routinely includes these in
all of its procurements.

Chuck

At 07:48 PM 5/10/2004, you wrote:
>Greetings!
>
>I'm struggling with the following scenario, and would love some input from
>this knowledgeable group...
>
>University is submitting a large proposal to a federal agency, pursuant to
>a Broad Agency Announcement.  Included in University budget are funds for a
>private entity to provide services (not research) to University, to include
>training on assembling of technologies (theirs) and training and advice on
>start-up of an assembly line.  Private entity includes a fee in their
>budget.  Should the services of the private entity be treated as a
>subcontract for calculation of F&A?  University rate is on MTDC.  Federal
>agency will be issuing a Cooperative Agreement.
>
>Am I making this harder than it needs to be?
>
>Thanks in advance for the education...
>
>Val Kettner
>
>xxxxxx@ndsu.nodak.edu
>
>
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Herbert B. Chermside, CRA
Special Asst. to VP-Research
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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