I agree with both Chuck and Pat.

Most of this issue would go away if we would consciously realize and convey that IDC recovery is for incurred expenses.

Similarly, this issue/confusion arises when folks talk about sharing/rewarding PI's with IDC recovered funds.  If an institution wants to use "its own money" to reward someone, it should just do so.  Likewise, in this instance, use of institutional funds for lobbying creates another issue entirely.

 David

>Date:    Tue, 18 May 2004 15:40:55 -0700
>From:    "Hawk, Patricia" <xxxxxx@OREGONSTATE.EDU>
>Subject: Re: allowable cost?
>
>Chuck, I share your opinion about the use of the F&A recovery also.
>Once the funds are collected from the Federal government, it becomes the
>recovery and then becomes institutional funds, not federal funds.
>
>I believe John's referring to the fact that you have to "keep track" of
>lobbying expenses as an unallowable cost for F&A rate proposal purposes.
>It has to be separately identified in the F&A rate proposal and go into
>the "other institutional activity"--where the rest of the unallowable
>activities go.  It's unallowable in terms of it being unallowable for
>reimbursement as either a direct or an indirect cost--the Federal
>government recognizes that colleges and universities do this, but it has
>to be identified and then "taken out of the equation."
>
>Also, I believe the percentage of F&A recovery on research resources
>only applies to those institutions shown in Exhibit B of OMB Circular
>A-21.
>
>Pat
>
>Patricia A. Hawk
>Training Specialist, Research Accounting
>Oregon State University
>306 Kerr Administration Bldg.
>Corvallis, OR  97331
>(phone) 541-737-5422
>(fax) 541-737-2069
>
>-----Original Message-----
>From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On
>Behalf Of Herbert B. Chermside
>Sent: Tuesday, May 18, 2004 1:19 PM
>To: xxxxxx@HRINET.ORG
>Subject: Re: [RESADM-L] allowable cost?
>
>I beg to disagree.  Lori was speaking of F&A recovery, not costs going
>into
>the F&A pools!  F&A RECOVERY is just paying you back for what you
>spent.  I'll admit that there is a commitment to spend 5% of F&A
>recovery
>on research resources, but that still does not make it "federal funds".
>
>Of course if these institutional funds are spent for lobbying, they must
>not get into the F&A base!
>
>Chuck

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