Hi Sarah,

The Divisions I manage do not have 3rd tier subcontracts, however we have
multi-center research with the NIH.  For our multi-center grants, the answer
is: yes the NIH does keep subcontracts somewhat separate...however under the
same award. So, same award number, and the notices of award to the main
university should show their own costs only, and additional notices listing
the subcontracts under their grant. If I remember correctly, the institution
receiving the subcontract will also receive their own notice of award from
the NIH.

Julie Edgerton
Associate Director, Finance & Administration
Department of Surgery
Div. of Plastic Surgery
Div. of Multi-Organ Transplantation
Stanford University

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of
Sarah Gause
Sent: Wednesday, August 16, 2006 7:21 AM
To: xxxxxx@hrinet.org
Subject: [RESADM-L] 3rd tier subcontract costs

I've been digging for a definite answer to a question, and thought I may get
an answer faster if I just check with the group...

My question is in regards to 3rd tier subcontracts, and where their costs
(direct and F&A) fall in the Primary institution's costs.

My Institution is submitting as a subcontract to the primary institution.
In addition, we also have a subcontract.

Questions is: do the direct costs from our subcontract only count towards
the Primary Institution's direct cost limit, or must the Primary consider
the F&A as part of their direct?

Does NIH keeps these separate - I think all subcontracts, no matter the
tier, would be treated the same.  However, there are mixed opinions
regarding this issue among the Institutions.

Has anyone experienced this before, or can any reference a policy that will
help.

Thanks!

Sarah Gause
Grants Coordinator
Ctr for Research in Nutrition and Health Disparities
Arnold School of Public Health
University of South Carolina

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