This is an age-ole problem that is common in most states and for most
universities.  To the best of my knowledge there is no federal
regulation that covers this.

At my university, we adhere to a policy that states if we are part of
the proposal submission to a federal agency, that has a state agency as
prime, we use our federal-negotiated rate.  If the state agency received
the federal funding without our participation, and later issues an RFP
for competitive projects, then we adhere to either 1) the State written
RFP if it includes a limitation of F&A, or: 2) The "standard" lower rate
the state Regents universities use when dealing with other state
agencies (8% TDC).

The question you are attempting to answer is:  "When is flow-through not
flow-through."  ISU answers that by saying "when we were not part of the
proposal process."  We still code the funds as federal, but we cave in
on the issue of F&A.

Joanne K. Altieri, Director
Office of Sponsored Programs Administration
1138 Pearson Hall
Iowa State University
Ames, IA 50011-2207
Phone:  (515) 294-7723
Fax:  (515) 294-8000
Email:  xxxxxx@iastate.edu

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org] On
Behalf Of Burchell valldejuli
Sent: Sunday, February 08, 2009 9:54 AM
To: xxxxxx@hrinet.org
Subject: [RESADM-L] F&A on State $$$ originating from CDC

We have been asked to submit for a contract bid from the State of CT.
The
monies originate from the CDC (federal) and bidders solicited via a
state
RFP. Our state partners want to know if we as contractees are obligated
to
pay the university's full federally negotiated rate OR if they (the
state)
may assign a different F&A when issuing the State RFP.

Thoughts?

~BURCH

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