We are S&W based indirect, and we count all student (we're all undergrads) wages (whether deemed wages or stipend) as taxable compensation and part of our F&A base.   So under this new NSF policy, we would budget the REU students as "participants" but we would apply our full F&A to their stipends.

Frances Vinal Farnsworth
Coordinator of Sponsored Research
Middlebury College
Middlebury, VT 05733
Email:  xxxxxx@middlebury.edu
Telephone:  802-443-5889
________________________________________
From: Research Administration List [xxxxxx@lists.healthresearch.org] on behalf of xxxxxx@mcdaniel.edu [xxxxxx@MCDANIEL.EDU]
Sent: Saturday, September 01, 2012 7:36 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation

Thank you Megan for posting this. Is there anyone else here that is a W&S base? I'm so used to MTDC I usually like to double check with a colleague to make sure I'm looking at things right.

Robin

On Aug 31, 2012, at 3:07 PM, "Cantwell, Megan" <xxxxxx@AASCU.ORG<mailto:xxxxxx@AASCU.ORG>> wrote:

NSF has updated the REU program page with this clarification:

NOTE ON INDIRECT COSTS IN REU SITE PROPOSALS
<image001.jpg>

In proposals submitted in response to solicitation NSF 12-569, indirect costs should be charged in accordance with the proposing organization's negotiated indirect cost rate agreement and the approved base as stated in that agreement. Questions about whether particular items (e.g., student stipends, housing costs, meal costs, travel costs) should be excluded from the application of indirect costs should be directed first to the office responsible for developing the organization's indirect cost rate proposal, and then--if that office cannot resolve the question--to the cognizant Federal agency responsible for negotiating the indirect cost rate agreement.
For all organizations, the underlying principle remains that the negotiated indirect cost rate agreement and the application base specified in that agreement determine whether indirect costs can be claimed on a particular expense line item. There is no overall NSF-imposed limitation that all Participant Support Costs are excluded from receiving indirect costs. Budget line items F (Participant Support Costs: F1 Stipend, F2 Travel, F3 Subsistence, and F4 Other) may or may not bear indirect costs in accordance with the negotiated rate agreement and the application base specified therein.

From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>] On Behalf Of Andrew M. Gray
Sent: Thursday, August 30, 2012 12:20 PM
To: xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>
Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation

"...since the new REU guidelines eliminated this allowance, the rules stated in the GPG now apply."

That is *not* what the NSF Policy Office has stated when we contacted them about this. They very clearly stated we can now charge indirect costs in keeping with our negotiated rate agreement, not that the rules in the GPG now apply.

Andrew

Here's the email from the NSF Policy Office (bold is my emphasis):
I’m responding on behalf of Jean Feldman. As stated in the Important Information and Revision Notessection of the solicitation, the solicitation has been revised to be consistent with NSF's long-standing policy regarding the reimbursement of administrative costs, which is full reimbursement of indirect costs based on the awardee's current Federally negotiated indirect cost rate agreement. As you noted, although the solicitation imposes no limit on indirect cost recovery it does limit the total project budget on a per-student basis.

You should charge in accordance with your Federally negotiated indirect cost rate. You should not, however, charge indirects on participant support costs unless your approved rate allows for this.

Please feel free to contact me if you have additional questions.

Anne Doyle
Policy Analyst
NSF Policy Office

=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=
Andrew M. Gray, CRA, CPRA
Director, UAF Office of Sponsored Programs
909 Koyukuk Drive / P.O. Box 757270
West Ridge Research Building, Suite 012
Fairbanks, AK 99775-7270

Phone:  (907) 474-1851<tel:%28907%29%20474-1851>
Fax:    (907) 474-5444<tel:%28907%29%20474-5444>
E-mail: xxxxxx@alaska.edu<mailto:xxxxxx@alaska.edu>
Web:    http://www.uaf.edu/osp/
=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=+=

On Thu, Aug 30, 2012 at 6:52 AM, schauerap <xxxxxx@muohio.edu<mailto:xxxxxx@muohio.edu>> wrote:
The NSF GPG specifically does not allow indirects to be charged on participant support costs.  Here are two direct quotes from this document.  The first is from the section on Participant Support (pg. II-14), and the second is from the section on Indirect Costs (pg. II-16):

"Generally, indirect costs (F&A) are not allowed on participant support costs."

"Exceptions to Basic Policy
No Indirect or Limited Reimbursement.  In some cases, however, NSF program solicitations may indicate no or
limited reimbursement for indirect costs.  In addition, NSF generally provides no amounts for indirect costs for the
following:
• participant support costs.  However, an allowance for indirect costs associated with participant support
costs may be established or negotiated in advance when circumstances indicate that the grantee could
be expected to incur significant expenses in administering participant payments (other than salary or
other direct expenses being reimbursed under the award). "

The old REU guidelines allowed for indirects to be requested at 25% of participant stipends, but since the new REU guidelines eliminated this allowance, the rules stated in the GPG now apply.

On Aug 29, 2012, at 12:24 PM, "Key, Diana" <xxxxxx@FSU.EDU<mailto:xxxxxx@FSU.EDU>> wrote:

Our rate agreement does not specify "participant support costs" per se. It states: " Modified total direct costs shall exclude equipment, capital expenditures, charges for patient care, student tuition remission, rental costs of off-site facilities,scholarships, and fellowships as well as the portion of each subgrant and subcontract in excess of $25,000."

Would you consider REU participant suppport to be scholarships or fellowships?

Diana

Diana L. Key
Associate Director
Sponsored Research Services
Florida State University
874 Traditions Way
Tallahassee, FL 32306-4166
P: 850-644-8648<tel:850-644-8648> F: 850-644-1464<tel:850-644-1464>

-----Original Message-----
From: Research Administration List [mailto:RESADM-<mailto:RESADM->xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>] On Behalf Of Young, Katherine S
Sent: Wednesday, August 29, 2012 11:11 AM
To: xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>
Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation

Remember the statement made by Jean Feldman...look at your rate agreement and if participant support costs are not explicitly excluded then charge it.  My rate agreement and that of my former institution do not exclude these costs.  We followed NSF's lead on other projects (NOT NSF) that included participant support costs on an elective basis.  With NSF now stepping away from this criteria I would recommend charging it as Jean states.

Kathy

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Bonnie Kwit
Sent: Wednesday, August 29, 2012 9:04 AM
To: xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>
Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation

I think you are all looking at this wrong.  The old REU program, as I know you are all award, allowed 25% indirect recovery on participant costs ONLY.
The new solicitation is allowing full indirect recovery based on your indirect cost rate agreement.  If your IDCR agreement is based on Modified Total Direct Costs that excludes participant support costs, tuition, and equipment.  So, for NSF to now allow full IDC recovery, is probably actually costing us more.  The majority of expenses for an REU are to be for Participant support costs.  At $500 per week for 10 student for a 10 week program for stipend only is $50K, then add the housing, meals, etc, all of which falls under the Participant support costs and all of which do NOT fall under the indirect cost calculation.

Bonnie Kwit
Grant and Contract Officer
Oakland University
Office of Research Administration
505 Wilson Hall
(248) 370-4116<tel:%28248%29%20370-4116>

-----Original Message-----
From: Research Administration List
[mailto:xxxxxx@lists.healthresearch.org] On Behalf Of xxxxxx@mcdaniel.edu<mailto:xxxxxx@mcdaniel.edu>
Sent: Wednesday, August 29, 2012 9:32 AM
To: xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>
Subject: Re: [RESADM-L] NSF REU Indirect Cost (F&A) Calculation

Okay - I have to admit this has left me completely confuzzled. Add to it my faculty member that has basically said "if we have to charge indirects, I'm not writing the grant".

Maybe a call to the program officer is in order.

Robin

On Aug 29, 2012, at 9:19 AM, "Young, Katherine S" <xxxxxx@ILSTU.EDU<mailto:xxxxxx@ILSTU.EDU>> wrote:

> 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<mailto: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<tel:770.499.3365> | Main line: 770-423-6738<tel:770-423-6738> |Fax: 770-499-3620<tel:770-499-3620>
> xxxxxx@kennesaw.edu<mailto:xxxxxx@kennesaw.edu> |www.kennesaw.edu/ogc<http://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<mailto: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<mailto:xxxxxx@ECU.EDU>>
> To: "xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch.org>"
> <xxxxxx@lists.healthresearch.org<mailto: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<mailto: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<tel:%28401%29%20874-5452> Phone
> (401) 874-7044<tel:%28401%29%20874-7044> Fax
> xxxxxx@mail.uri.edu<mailto:xxxxxx@mail.uri.edu<mailto:xxxxxx@mail.uri.edu%3cmailto:xxxxxx@mail.uri.edu>>
>
> [clip_image001]
>
>
> From: Research Administration List
> [mailto:xxxxxx@lists.healthresearch.org]<mailto:[mailto:xxxxxx@lis<mailto:xxxxxx@lis>
> ts.healthresearch.org<http://ts.healthresearch.org/>]>
> On Behalf Of Wood, Roger
> Sent: Tuesday, August 28, 2012 3:53 PM
> To:
> xxxxxx@lists.healthresearch.org<mailto:xxxxxx@lists.healthresearch<mailto:xxxxxx@lists.healthresearch.org%3cmailto: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<tel:%2B1%C2%A0%20518.%20713.%204200%C2%A0%C2%A0%20ext%C2%A0%20150>
> f    +1  518. 713. 4201<tel:%2B1%C2%A0%20518.%20713.%204201><span style="color:#003F
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