Each type of recipient has a different set of cost principles, as you
have listed.  The administrative circulars (A-110, A-102) require
that the cost principles awarded in subawards  be those of the
recipient's type of business.

And if the school system is procuring from you, rather than
subawarding, F&A is still part of your cost, even though there is no
flow down of regulations in a procurement.

Chuck

At 01:09 PM 3/23/2006, you wrote:
>Hi all -- I hope you can help us with a sticky situation.
>
>We work closely with a school district, whose new business manager
>insists that federal regulations prohibit them from giving indirect
>costs to their subcontractors. Of course we think this is
>ridiculous, but we're struggling to find the right chapter and verse
>in OMB Circulars A-87 (governing ESDs, among other government
>entities), A-21 (governing higher ed), or EDGAR. We're still
>looking, but I'd greatly appreciate any guidance. Otherwise, we
>simply won't be able to work with the ESD, and I doubt anyone else
>will work with them either.
>
>--
>Diane M. Schmitz
>Grant & Research Development
>Eastern Washington University
>Cheney WA 99004-2444
>Phone:  (509) 359-2517  * Fax:  (509) 359-6693
>
>
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Herbert "Chuck" Chermside, CRA
Director Emeritus, VCU Sponsored Programs
Executive Director, Research Administrators Certification Council
1915 Robindale Rd.
Richmond, VA 23235-3931
804-320-5502
xxxxxx@verizon.net

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