Dear Ellen,

My recent experiences with US Ed leave me a bit suspicious about a TDC
base.  Assuming that your federally-negotiated rate exceeds 8%, you
might look at EDGAR 34 CFR 75.562 for the application of 8% on training
grants. ("For the purposes of this section, a modified total direct cost
base is defined as total direct costs less stipends, tuition and related
feeds, and capital expenditures of $5,000 or more.)

If the US Ed program to which you are applying has a statutory
requirement prohibiting the use of Federal funds to supplant non-Federal
funds, you need to use a "restricted" indirect cost rate computed under
34 CFR 76.564-9.  (It doesn't matter how you might think this
"supplement v.s. supplant" issue should be decided from a logical
standpoint.  If US Ed classifies the program as subject to this
statutory requirement, end of discussion.  You can find the language in
the program solicitation, normally under the Eligibility section.)  In
this case, the 8% is applied to total direct costs minus "capital
outlays, subgrants, and other distorting or unallowable items as
specified in the grantee's indirect cost rate agreement." (from 76.569)

If you still don't have the answer to your question, contact the program
person mentioned in the solicitation or Richard Mueller, head of US Ed's
indirect costs group.

(If you indeed have found a solicitation that says 8% TDC, I'd love to
see it!)

Good luck,

Kathy Cataneo
University of New Hampshire
xxxxxx@unh.edu

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On
Behalf Of Ellen Rogers
Sent: Thursday, April 13, 2006 2:03 PM
To: xxxxxx@HRINET.ORG
Subject: [RESADM-L] F&A question

We have a proposal going out to Dept. of Education which limits F&A to
8%
of TDC.  The budget happens to include a subaward each year of the
project.  Do we apply 8% to the first $25,000 of the sub or to the
entire
sub amount?  A reference would be great if you have one.

Ellen Rogers
University of Notre Dame
574/631-5488

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