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Re: allowable cost? Herbert B. Chermside 19 May 2004 09:58 EST

WOAH!!!   DANGER!!!

The problem is differentiating between F&A charged (or reduced, or waived),
and Recovered F&A.

The F&A Revenue recovered is the institution's to do with as it
will.  Though you have to be careful that the use doesn't contravene F&A
rate development rules.  I suggest, to avoid confusing this revenue with
F&A Charged that you decide to give that revenue account a name that
CLEARLY differentiates, so those who are not skilled in sponsored programs
finance don't get confused.  Maybe "Recovered Indirect" -- that tells where
it came from but avoids "F&A" in the name.  I also suggest that the revenue
in this account is moved to other accounts (as revenue or budget authority)
and spent from there.  Much cleaner!  This also makes sure that when spent,
the purpose of the expenditure goes into the correct F&A pools (including
purposes unallowable under A-21 for F&A pools).  And decisions about using
this recovery should be made at an institutional level.  One use for some
of it might be to go back to the dean, chair, and/or PI whose project(s)
earned it.  Or you can move it to pay for some of the utilities, library,
or whatever pools generated it.

Michelle, technically you can use these RECOVERIES in the ways you
suggested, IF the institutional policies provide for it.  For example, some
of the recovery may go into a pool from which matching funds (I assume you
mean specifically Mandatory Committed Cost Sharing) can be committed; I
suggest this use be under the control of, say, a dean, or in a small
institution, even higher.  "Faculty may pay themselves salary" sounds like
you are confusing these recoveries with F&A charges, but if the recovery
went to a department chair, he could use the funds to pay (non-sponsored)
salaries, or, better yet, to pay teaching faculty who need to cover his
department's teaching responsibilities when faculty on sponsored programs
get release time for paid sponsored work.

Chuck

At 09:45 AM 5/19/2004, you wrote:
>Good morning..you mean F&A can be used as matching funds on federal
>awards; that faculty may pay themselves salary? Thanks
>Michelle
>
>At 04:15 PM 5/18/2004 -0400, you wrote:
>>Recovered F&A is yours to use in any way you see fit.  It is NOT "federal
>>funds" in the manner meant when regs say you can't use federal funds to
>>lobby.  However, use should follow whatever policies you have internally
>>for using institutional funds for lobbying.
>>
>>Chuck
>>
>>
>>At 03:52 PM 5/18/2004, you wrote:
>>>Good Afternoon,
>>>
>>>Can one use recovered F & A costs to pay a consultant who will be doing
>>>what could be defined as lobbying activities?
>>>
>>>Thank you,
>>>
>>>Lori Messer, MPA, CRA
>>>Director
>>>Research & Sponsored Programs
>>>Wake Forest University
>>>P.O. Box 7528 Reynolda Station
>>>Winston-Salem, NC  27109
>>>(336) 758-5888
>>>(336) 758-1959 fax
>>>
>>>
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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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>>subscription information and a web-searchable archive, are available
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>
>Michelle M. Plaud, CRA
>Assistant Director
>Grants & Contracts
>University of Massachusetts Dartmouth
>508 999-8509 (voice)
>508 999-8868 (fax)
>

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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