Robin,

The new electronic submission guidelines (which can be as confusing as
all get out) have a section starting on page I-87-" 4.8 Special
Instructions for Preparing Applications with a Subaward/Consortium".
This section states that "A complete subaward/consortium budget
component (including the budget justification section) should be
completed by each consortium grantee organization."  In addition, they
also explain the consortium F&A exclusion with budget limitations:

"NIH continues to support the policy established in April 2004,
(revised in November 2004) regarding applications that involve
consortium/contractual F&A costs (See NOT-OD-05-004). This policy allows
applicants to exclude consortium/contractual F&A costs when determining
compliance for any application where a direct cost limit applies. The
use of the SF424 (R&R) application with separately submitted
subaward/consortium budgets allows NIH to take advantage of a system
validation for this policy. When an application is submitted in response
to a program with a direct cost limit, the eRA system will perform the
calculation by taking the total direct costs requested by the
prime/parent organization in their detailed budget, and subtracting all
subaward/consortium F&A from each and every subaward budget attached.
When the validation calculation equals or exceeds the respective direct
cost limit, the application will receive a warning."

I am sure I have just brushed the surface here, but the remaining
portions of this section should provide further answers.

I hope this helps!
Lea

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