True. I would suggest using your negotiated indirect cost rate agreement as guidance on what to exclude from your IDC calculation. If you are awarded, the NSF program officer will more than likely notify you of a need to change the budget accordingly.

Sharon D. Smith, M.S., CRA
Research Development Specialist
MTSU Office of Research Services
(615) 898-5894 (Office)
(615) 898-5028 (Fax)

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Laura Letbetter
Sent: Wednesday, August 29, 2012 9:10 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation

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

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-----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

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