Yes, you are correct that specific programmatic guidelines prevail over general guidelines. What I am questioning is whether the specific REU guidelines really mean that participant support can be included: "Indirect Costs: Please note an important change to the treatment of indirect costs that is incorporated in this Research Experiences for Undergraduates (REU) program solicitation. The REU program's previous limitation on indirect costs (i.e., an administrative allowance, limited to 25% of the participant support stipend amount, in lieu of indirect costs) has been removed. This solicitation imposes no limit on indirect cost recovery but limits the total project budget on a per-student basis. NSF's long-standing policy regarding the reimbursement of administrative costs is full reimbursement of indirect costs, based on the awardee's current Federally negotiated indirect cost rate agreement. To ensure consistency with Foundation and Federal-wide policies, proposals submitted in response to this program solicitation are subject to the awardee's current Federally negotiated indirect cost rate." The paragraph references NSF's "long-standing policy," and part of their long-standing policy is the exclusion of participant support. If this paragraph really means that we don't have to exclude participant support from our indirect cost calculation, then I am happy to be wrong, because not having to exclude participant support would certainly be better for the institution. I just don't think it's 100% clear, and given the purpose of the REU program, it is difficult for me to believe that NSF really means this. I can't think of any other program where NSF allows indirects on participant support. -----Original Message----- From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Young, Katherine S Sent: Wednesday, August 29, 2012 9:20 AM To: xxxxxx@lists.healthresearch.org Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation The PAPP are general guidelines but when there are specific programmatic guidelines, they prevail, e.g. International Programs exclude F&A on foreign travel, but you do not generally exclude it under a standard program. Kathy -----Original Message----- From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Laura Letbetter Sent: Wednesday, August 29, 2012 8:05 AM To: xxxxxx@lists.healthresearch.org Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation Yes, the new REU guidelines say to use your rate, but the PAPP says participant support is excluded from indirect costs. Many NSF solicitations say "Indirect Cost (F&A) Limitations: Not Applicable," but that doesn't mean you can collect indirects on participant support. Did Jean Feldman specifically say that the PAPP guidance on indirects does not apply to the REU solicitation? Laura Letbetter Director, Proposal Development Office of Research Kennesaw State University, 1000 Chastain Road, MD 0111 Kennesaw Hall, Room 3419 (deliveries), Kennesaw, GA 30144-5591 Direct: 770.499.3365 | Main line: 770-423-6738 |Fax: 770-499-3620 xxxxxx@kennesaw.edu |www.kennesaw.edu/ogc This email, and any attachments, is intended only for use by the addressee(s) named herein and may contain privileged and/or confidential information. If you are not the intended recipient of this email, you are hereby notified that any dissemination, distribution or copying of this email, and any attachments thereto, is strictly prohibited. -----Original Message----- From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Young, Katherine S Sent: Tuesday, August 28, 2012 6:24 PM To: xxxxxx@lists.healthresearch.org Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation You should look at the updated guidelines..... Sent from my Verizon Wireless Droid -----Original message----- From: "Betcher, Gina I" <xxxxxx@ECU.EDU> To: "xxxxxx@lists.healthresearch.org" <xxxxxx@lists.healthresearch.org> Sent: Tue, Aug 28, 2012 22:21:59 GMT+00:00 Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation Participant Support is exempt from indirect costs. From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Jill Diehl Sent: Tuesday, August 28, 2012 4:32 PM To: xxxxxx@lists.healthresearch.org Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation If they are budgeted as participant support costs, which is what the NSF REU RFP referes to them as (the student stipend and tuition), wouldn’t they be excluded per NSF policy? Jill Diehl Grants & Contracts Specialist II Sponsored Projects Office 70 Lower College Road, 2nd Floor Kingston, RI 02881 (401) 874-5452 Phone (401) 874-7044 Fax xxxxxx@mail.uri.edu<mailto:xxxxxx@mail.uri.edu> [clip_image001] From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org]<mailto:[mailto:xxxxxx@lists.healthresearch.org]> On Behalf Of Wood, Roger Sent: Tuesday, August 28, 2012 3:53 PM To: xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org> Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation Jean Feldman just mentioned (yesterday at FDP) that NSF was getting this question quite a bit. And, her answer was "look at your Indirect Cost Rate Agreement letter. If the costs are included in your rate, then include them; if the costs are excluded from your rate, then exclude them. Period." (Perhaps that's not really a direct quote, but its certainly the message she conveyed!) The answer would depend on whether those particular costs are included or excluded in your institution's rate agreement and thus the answer might vary from institution to institution. Roger ________________________________ Roger Wood Sr. Product Manager v +1 518. 713. 4200 ext 150 f +1 518. 713. 4201<span style="color:#003F ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ====================================================================== ====================================================================== 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.healthresearch.org (click on the "LISTSERV" link in the upper right corner) A link directly to helpful tips: http://tinyurl.com/resadm-l-help ======================================================================
