Email list hosting service & mailing list manager


Re: 3rd tier subcontract costs Sarah Gause 16 Aug 2006 10:51 EST

Thank you all for your responses.

I finally spoke with NIH - with two different responses,  but enough guidance to answer my questions.

While NIH policies were not setup with the thought of 3rd tier subcontracts, they are possible - and done.  However, due to potential monitoring problems by the primary institution, they are discouraged.

For the purposes of a direct costs limit on Primary grants, each entity's directs should (I stress should, since it is all dependant on the initial reviewer's interpretation of the policies) only fall under the direct of the primary, for the purposes of submission (even though, in the accounting of everything, F&A do indeed turn into direct costs).  If anyone does do this, just be sure to justify everything appropriately.

Thanks again!
~Sarah

>>> John Sites <xxxxxx@earthlink.net> 08/16 11:36 AM >>>
Sarah,

In my pre-award days we always treated the entire cost of the subcontract as part of our direct cost.  We then took F&A on the first 25K in accordance with our F&A agreement and A-21.

Regardless of the "tier," the costs should be reflected as a direct cost to all tiers above, each adding its F&A, as appropriate, along the way.

Of course, at some point the number of tiers can become a burden when the F&A begins to pile up !!

I hope this helps!

john

John Sites
Huron Consulting Group

-----Original Message-----
>From: Sarah Gause <xxxxxx@GWM.SC.EDU>
>Sent: Aug 16, 2006 10:20 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
>
>
>======================================================================
> Instructions on how to use the RESADM-L Mailing List, including
> subscription information and a web-searchable archive, are available
> via our web site at http://www.hrinet.org (click on "Listserv Lists")
>======================================================================

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================