Carolyn Witt . * * * * This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient(s) please contact the sender by reply email and destroy all copies of the original message. Thank you. * * * * ----- Original Message ----- From: Research Administration List <xxxxxx@hrinet.org> To: xxxxxx@hrinet.org <xxxxxx@hrinet.org> Sent: Thu May 03 11:41:49 2007 Subject: Re: [RESADM-L] Direct vs. indirect charges? I would guess that it is “Mark” – but that is just a guess. ________________________________ From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Carolyn Elliott-Farino Sent: Thursday, May 03, 2007 8:25 AM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] Direct vs. indirect charges? MBEREZAN (I can't tell what your name is), Normally you wouldn't charge sponsored projects time directly to a project because that is covered under your F&A. I guess I have two related comments: 1) Some projects do require a lot of work (not to mention headaches) — that's part of the game. So you may end up devoting a considerable amount of time on this project. Hopefully it's paying full indirects. 2) "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." This doesn't sound like sponsored program staff work. It's not your responsibility to run the project. There should be a PI/PD, and possibly an admin person hired directly for this project. I don't see any justification (not even getting into whether it's allowable) for you to direct charge your time. Perhaps I've missed something. Carolyn >>> xxxxxx@IUP.EDU 5/2/2007 4:37:43 PM >>> 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. ====================================================================== 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") ====================================================================== ====================================================================== 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") ====================================================================== This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient(s) please contact the sender by reply email and destroy all copies of the original message. Thank you. ====================================================================== 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") ======================================================================
