We are a corporate, nonprofit organization affiliated with a state system
university (separate but affiliated).  The university pays for our services
out of their returned indirects to serve as their Office of Sponsored
Projects.  Our organization (the separate 501) found an opportunity to
contract with a federal agency which will include a subaward to the
affiliated university.  The Institute will be responsible for all terms &
conditions.  Contracting with federal agencies is fairly new to the
university and there is a lot of uncertainty regarding direct vs. indirect
charges and what is justifiable and appropriate.  Our staff is responsible
for facilitating all aspects (pre and post award, including legal signatory)
of sponsored agreements for university personnel.  In essence, the
university outsources these responsibilities to our organization.

Here is the scenario:  Under this contract, we (the separate nonprofit) will
be required to perform duties over and above our regular job duties to
successfully execute the new opportunity.  Based on the circulars, program
management and/or direct charging of administrative time is appropriate and
required on "major projects" (which this definitely meets) and when
"personnel or duties are readily identifiable to the project".  I am
proposing charging a % of my time as an SME (with extensive applicable
experience) and a contracting officer's time for the additional negotiations
and coordination work that will be required to ensure the project runs
smoothly and all required deliverables are met.  At this point, it is a
'pilot' project with the anticipation (by the agency) of a fast & large
growth potential.  It could easily become a full-scale program (i.e., double
or triple in size within a semester's time).  There will be a lot of
developmental time, including travel, communication, networking, periodic
reporting, coordination among faculty & admin & agency reps, etc. within the
period of performance to ramp up to full-scale.

It is our understanding that if we don't charge these costs, they will be
buried into the F&A pool and the costs incurred by this project will be
spread among all our other sponsored projects that pay F&A.  Some argue that
these costs should not be direct charged to the project and that they fall
under F&A because our services are paid for out of their recovered F&A.
Obviously the university falls under A-21 and we, a non profit, fall under
A-122.  In addition, does anyone have any guidelines or recommendations on
how to determine what % to charge?

Can folks please provide some feedback confirming (or not) that we are in
compliance with this proposal and if it is a commonly accepted practice?  I
would appreciate responses either to the listserv or direct to my email at
xxxxxx@iup.edu.

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