Dear all,
 I know this question was discussed here earlier this year but
have been unable to locate the discussion in the archives.  Please bear
with me.  We are responding to an RFA put out by the Department of
Education's Institute of Education Services.  In this RFA, a section
titled "Special Requirements" states that:  The Institute anticipates that
the majority of the research will be conducted in field settings.  Hence,
the applicant is reminded to apply its negotiated off-campus indirect cost
rate, as directed by the terms of the applicant's negotiated agreement."
 Our researchers are arguing that they are doing over 50% of the
work off-campus and therefore the off-campus rate should apply and besides
the RFA says to use the off-campus rate.  The controller's office is not
convinced.  If the researchers can truly justify that over 50% of their
time is spent in the field is it legitimate to use the off-campus rate?
Or, is there a greater test that I am missing?
 Just FYI our indirect rate is on a salary and wages basis and
the off-campus definition included in our indirect agreement is worded as
follows:  OFF-CAMPUS DEFINITION:  For all activities performed in
facilities not owned by the institution and to which rent is directly
allocated to the project(s), the off-campus rate will apply.  Grants or
contracts will not be subject to more than one F&A cost rate.  If more
than  50% of a project is performed off-campus, the off-campus rate will
apply to the entire project.
 Thanks for your help.
Jean

Jean M. Murphy
Director of Pre-Award Services
Wellesley Centers for Women
http://www.wcwonline.org
E-mail:  xxxxxx@wellesley.edu      Phone:  781-283-2508     Fax:
781-283-2504

Wellesley College, Cheever House, 106 Central Street, Wellesley, MA  02481

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