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F & A Costs Fixed for Life Kim Dunbrook-Babbie 05 Jun 2007 09:42 EST

Per A1
7. Fixed rates for the life of the sponsored agreement.
a. Federal agencies shall use the negotiated rates for F&A costs in
effect at the time of the initial award throughout the life of the
sponsored agreement. "Life" for the purpose of this subsection means
each competitive segment of a project. A competitive segment is a period
of years approved by the Federal funding agency at the time of the
award. If negotiated rate agreements do not extend through the life of
the sponsored agreement at the time of the initial award, then the
negotiated rate for the last year of the sponsored agreement shall be
extended through the end of the life of the sponsored agreement. Award
levels for sponsored agreements may not be adjusted in future years as a
result of changes in negotiated rates.

b. When an educational institution does not have a negotiated rate with
the Federal Government at the time of the award (because the educational
institution is a new grantee or the parties cannot reach agreement on a
rate), the provisional rate used at the time of the award shall be
adjusted once a rate is negotiated and approved by the cognizant agency.

Question
Is everyone interpreting this to mean that we can take the Overhead
(FA) rate that is awarded to us over the life of the grant even if our
negotiated rate changes (including a  decrease) during the award
period?

Thank You for your help

Kim Babbie

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